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Citation: UNDP Bangladesh and UN WOMEN Bangladesh 2018. Report on Environmental Impact of Rohingya Influx.
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Report on

ENVIRONMENTAL IMPACT OF
ROHINGYA INFLUX
March 2018
Dhaka, Bangladesh

FOREWORD
Cox’s Bazar in Bangladesh is the world’s largest refugee camp. It has been hosting
over one million Rohingyas since 25 August 2017. The emergency is putting
immense pressure on scarce natural resources in the area, resulting in degraded
natural forests, barren hills and an emerging water crisis. This situation demands
immediate investments in restoring the environment and ecosystem as part of the
Government of Bangladesh’s humanitarian response in Cox’s Bazaar.
Sensing the urgency for measures to prevent further degradation and to support
early restoration, we, at UNDP, undertook this Environmental Impact Assessment
with the aim that it would help development actors programme early response. It
is one of our three studies through which we focus on the host community’s needs
in the area. Throughout the study, we coordinated closely with field offices of the
Department of Environment and Forest Department.
Our report highlights key risks to the area’s environment and ecosystem. This
includes alarming groundwater depletion and contamination, deforestation
of protected areas, loss of wildlife habitat and rapid biomass reduction. Our
assessment provides feasible recommendations to slow down and arrest escalating
environmental challenges. In doing so, we believe it will help the Government,
development partners and relevant policy makers to address long-term
consequences following the crisis.
As part of the 2018 Joint Response Plan, we have several pipeline projects for
restoring the ecology. These are part of our wider approach for assisting Cox’s
Bazaar’s host communities. Our other projects include improving community
resilience through Cash-for-Work initiatives, supporting governance structures and
putting effective solid waste management systems in place.
We plan to partner with the Ministry of Environment and Forests, Ministry of Foreign
Affairs, Ministry of Disaster Management and Relief, and relevant ministries and
agencies to restore the degraded environment and ecosystem.
We are pleased that this report has been finalized following extensive consultations
and meetings. We hope that the measures proposed in this report will be followed
up with concrete action.

SUDIPTO MUKERJEE
Country Director
UNDP Bangladesh

The Rohingya crisis in which an estimated 886,778 Rohingya people crossed the
border into Coxâ&#x20AC;&#x2122;s Bazar since August 2017 is being referred to as one of the biggest
humanitarian emergencies in the world today. As is the case in any humanitarian
crisis, the women and girls are disproportionately being affected because crisis
reinforce, perpetuate and exacerbate pre-existing, persistent gender inequalities and
gender-based violence and discrimination. Similarly, the environmental impact of
the crisis is affecting women and girls differently from men and boys. Girls are having
to go extra miles to collect cooking fuel and are exposed to greater risks of violence
in the process. The use of firewood for cooking inside the temporary shelters with
poor ventilation is exposing women who are confined in the enclosed space to
hazardous fumes and are creating health problems.
Initiated by the Ministry of Environment and Forest (MoEF) of Bangladesh, together
with UNDP and UN Women, this report is based on a Rapid Environmental Impact
Assessment (REIA) conducted late 2017. It reveals impact of the crisis to the
ecosystem starting from degradation of forest and loss of vegetation and wildlife,
to other physical impacts such as water scarcity, challenges with maintaining
sanitation including the lack of functional latrines and solid waste management,
and the hazards related to the use of firewood for cooking. UN Women reviewed the
challenges from a gender perspective and have highlighted specific gender-based
issues and risks for women, such as the ones mentioned above.
UN Womenâ&#x20AC;&#x2122;s wish is two-fold. First, we hope that the recommended actions
specifically addressing the challenges that women face would be implemented.
Second, we hope that women will have equal opportunity to join the training
and awareness raising activities recommended in the study, play an active part in
decision-making of which recommendation will be implemented as priority, and
benefit from employment opportunities that may be created when implementing
the recommendations to restore the ecosystem.

ACKNOWLEDGMENTS
This study was initiated by the Ministry of Environment and Forests (MoEF), the Government
of Bangladesh (GoB), and UNDP and UN Women, with the support of UN Environment and
OCHA and with the engagement of the following experts: Alexandre Chaikine, Mohammad
Reazuddin, Md. Danesh Miah, Md. Sajidur Rahman and Arnold Egli (deployed through the UN
Environment / OCHA Joint Unit with the support of the Swiss Agency for Development and
Cooperation).
The authors gratefully acknowledge the support and attention they received from all the
sponsor agencies during the course of the study. The authors wish to acknowledge their
sincere gratitude in particular to Kyoko Yokosuka, Md. Khurshid Alam and Arif M. Faisal of
UNDP and Dilruba Haider of UN Women for their constant support and knowledge-based
interventions. Arif M. Faisal was with the study team throughout their time in the field as
well as in the consultation process, and deserves special thanks for his immense technical
contribution in finalization of the report. The author also acknowledges the guidance and
valuable inputs received from Mr. Abdullah Al Mohsin Chowdhury, Secretary (in Charge),
Dr. Sultan Ahmed, Additional Secretary, Dr. Md. Mohiuddin, Joint Secretary (Forests),
Dr. ANM Abdullah, Deputy Secretary (Forest) of the Ministry of Environment and Forests.
Our appreciation also goes to the Coxâ&#x20AC;&#x2122;s Bazar units of the Department of Environment (DoE)
and the Forest Department (FD) for providing baseline data and other relevant information.
We would like to acknowledge support received from Mr. Ali Kabir Haider, DFO, Coxâ&#x20AC;&#x2122;s Bazar
South Forest Division. DoE undertook the sampling of ground water and surface water and
provided the test results. FD shared valuable information on forest land use in the study
area. The authors are also greatly indebted to Md. Anwar Hossain and Abdul Malek, for their
valuable contribution during the field data collection. The authors sincerely acknowledge the
support they also received from the Arannayk Foundation Dhaka and the International Union
for Conservation of Nature (IUCN) Dhaka, during the course of the study.
The authors wish to express their special thanks to Kristofer Johnson (FAOBD) and Rashed
Jalal (FAOBD) for their useful discussions with the study team and for providing crucial input in
the development of the land cover GIS model. Sincere thanks are also due to Gavin Reynolds
(Red Cross Federation) for his useful discussion on mitigation priorities and for providing the
results of ground water analyses. Gratitude is also due to Abu Naim Md. Shafiullah Talukder
(Sector & Cluster Coordinator-WASH) for providing valuable inputs in the project scoping.
We also apreciate Mayeesha Azhar of UNDP for providing necessary logistical support and
keeping records of stakeholder discussions.

EXECUTIVE SUMMARY
The Rapid Environmental Assessment Study was initiated by the Ministry of
Environment and Forest (MoEF) of Bangladesh and by UNDP and UN Women to
assess the environmental impacts of the Rohingya influx into Bangladesh and
propose a series of actions to address the high environmental risks related to the
influx. The study received additional support from the environmental emergency
response mechanism of the UN Environment/OCHA Joint Unit, through the Swiss
Agency for Development and Cooperation.
The UNHCR Environmental Guidelines (1996) state that the environmental
impacts of an influx of asylum seekers in host countries include: “uncontrolled
fuelwood collection, poaching, and overuse of limited water supplies. These impacts
have placed serious strains on the ecosystems in many regions, including some
unique areas set aside by local governments as parks or reserves or even sites
recognized by UNESCO as World Heritage Sites. In the worst case, these activities, if
continued, could result in irreversible losses of productivity, the extinction of species
of plants or animals, the destruction of unique ecosystems, the depletion or longterm pollution of ground water supplies, or a variety of other destructive outcomes”.
The Rapid Environmental Impact Assessment (REIA) team found this description
to be an accurate reflection of the situation with regard to the Rohingya influx,
where the consequences of the influx are unfolding at an alarming rate and on
an enormous scale.
The study addresses environmental and related gender-based issues and health
risks. It aims to: establish a baseline of the environmental context in which
Rohingya1 asylum seekers have sought refuge;2 identify the current and potential
environmental impact of the influx; and propose measures that the Government
of Bangladesh, UN and other partners can implement to mitigate or offset the
current crisis.
The assessment methodology was informed by UNDP’s Social and Environmental
Standards (2015) and UNHCR’s Environmental Guidelines. The study draws
on existing information, stakeholder feedback, results from reconnaissance
Rohingya refugee are referred here as ‘forcibly displaced Myanmar nationals’ as per government recommendation.
However the word “Rohingya” is used here throughout the report.

1

The detailed baseline conditions can only be defined within a full scale environmental assessment work. This rapid
assessment provides only indicative findings and is based on a limited set of available data.

survey to the influx area and limited field surveys,
including surface and ground water sampling and
analyses, and the responses of residents from host
communities and Rohingya to a questionnaire
about use of wood for fuel and construction,
encounters with wildlife, and poaching. The scope
of the study was limited by the short period of time
available for the collection of baseline information,
and by the scarcity and quality of this information.
The assessment was conducted on a qualitative
level for physical environmental impacts and on
a semi-quantitative level for cumulative impacts
on ecosystems (using aerial photos, satellite
images, ground truthing, GIS data and maps). The
description of environmental baseline conditions is
based on available information and the description
of the current state of the environment after the
Rohingya influx is presented as part of the baseline.
A simple model using the available biomass,
land cover information and cooking fuel demand
was developed and used to assess the speed of
potential forest degradation caused by excessive
fuelwood collection.
Due to time constraints a comprehensive
environmental impact assessment was not
conducted. Rather, a rapid environmental impact
assessment is conducted and hence this report
has some limitation. Environmental losses and
damage caused by Rohingya influx is therefore
not evaluated and investment required for
implementation of environmental management
plan is not costed in this report.

Eleven environmental impacts were identified that
have been or could potentially be exacerbated
by the Rohingya influx. Six of these were
physical environmental impacts on: ground
water; surface water; acoustic levels; indoor air
quality; solid waste management; and soils and
terrain; and the remaining five were impacts on
ecosystems: natural forests; protected areas and
critical habitats; vegetation; wildlife; and marine
and freshwater ecosystems. Key risks were
pinpointed and assessed based on the rating
of their impact. The following risks associated
with the physical environmental impacts were
assessed as high: ground water depletion; ground
water contamination; poor indoor air quality;
poor management of sewer sludge; removal
of soils and terrain; and changes in terrain.
Impacts on ecosystems with high associated
risks were: deforestation and forest degradation;
encroachment onto and resource extraction from
protected areas; changes in land cover; rapid
biomass reduction; loss of species; loss of wildlife
habitat and shrinkage of wildlife corridor; and
mortality risks for wildlife.
Most of the physical environmental impacts appear
to be reversible, although those on soils and
terrain may require considerable time to return
to their baseline levels. The denuded landscape
will have reduced water retention capacity
which may impact ground and surface water in
the area. Paramount to any reversal will be the
implementation of closure of the Rohingya camps
and the initiation of land reclamation plans.

9

The study identified the following
gender-based issues: the health risks
of inhaling smoke from cooking inside
poorly ventilated shelters; the physical
demands of firewood collection; and
a lack of separate bathing and toilet
facilities for women. Overuse of natural
resources such as the unregulated
collection of firewood and the extraction
of ground water may give rise to
conflicts between the Rohingya and
the host communities, which could
disproportionally affect women who are
one of the most vulnerable groups of the
population.

social forestry, reforestation and artificial
natural regeneration of shrub dominated
areas, afforestation along the coastal line
and agroforestry in the village common
forests. Other measures include: to
develop and implement closure and
reclamation plans for abandoned camps,
including landscaping, turfing in barren
hills, improve drainage, soil restoration,
and reforestation; to establish designated
areas for bamboo afforestation and
promote bamboo regeneration projects;
and to consider enhancement of natural
habitats in other areas of Bangladesh to
ensure no net loss in biodiversity.

The study outlines a number of
recommendations to implement
mitigation measures and offset
programmes.

Current experience in managing influxes
shows that at the stage when asylum
seekers become repatriated or integrated,
funds are scarce for the closure and
reclamation of the abandoned camps
and associated facilities as well as for the
reforestation of degraded lands and the
conservation of wildlife habitat. Sufficient
resources will need to be secured to
ensure that reinstatement of the land is
adequately supported after the Rohingya
repatriation.

One crosscutting mitigation measure to
address the physical impacts of the influx
is to provide alternative fuel and cooking
stoves and/or a dedicated space for
community cooking. This would improve
air quality in the shelters, eliminate the
need for fuelwood collection from forests
and protected areas, and remove the
associated gender-based health and
safety risks. Improved planning and living
standards would address issues of access
to potable water, sanitation and solid
waste management.
The immediate impact on ecosystems
in the area is cumulative in nature and
less visible than the physical impacts
of the influx. Proposed mitigation, for
example strict rules of resource use in
protected areas, requires addressing the
land and resource use patterns of both
the host communities and the Rohingya.
To improve the degraded forest habitat
and compensate for the forest areas lost
beneath the campsâ&#x20AC;&#x2122; footprint, proposed
actions include assistance to community/

10

Extensive environmental management
and detailed long-term monitoring
programmes are recommended to
confirm and quantitatively define
the results of this indicative Rapid
Environmental Assessment Study, and
mitigate the environmental loss and
damage from the influx. The programmes
will be integrated in the UN Joint
Response Plan process and led by the
Ministry of Environment and Forest
(MoEF) and the Ministry of Disaster
Management and Relief with support
from the Department of Environment
(DoE), the Forest Department and the
Department of Disaster Management and
other associated line agencies.

Area where the impact of activity is assessed. It usually
includes the primary project site(s) and related facilities;
areas and communities potentially affected by cumulative
impacts from further planned development in the
geographical area that are realistically defined at the time
the assessment is undertaken; and areas and communities
potentially affected by the impact from unplanned but
predictable developments caused by the project that may
occur later or at a different location.

Biodiversity

The variability among living organisms from all sources
including terrestrial, marine and other aquatic ecosystems
and the ecological complexes of which they are part; this
includes diversity within species, between species and of
ecosystems.

Critical habitat

Areas with high biodiversity value, including habitat
required for the survival of critically endangered or
endangered species; areas having special significance for
endemic or restricted-range species; sites that are critical
for the survival of migratory species; areas supporting
globally significant concentrations or numbers of
individuals of congregatory species; areas with unique
assemblages of species or that are associated with
key evolutionary processes or provide key ecosystem
services; and areas having biodiversity of significant social,
economic, or cultural importance to local communities.

Cumulative impact

Changes in the environment caused by an activity in
combination with other past, present and future activities.
The combination of multiple impacts from existing
projects, the proposed project, and anticipated future
projects that may result in significant adverse and/or
beneficial impacts that cannot be expected in the case of
a stand-alone project.

Any species whose range is restricted to a limited geographical area. An endemic
species is one that has ≥ 95 percent of its global range inside the country or region
of analysis.4

Denudation

Process that causes the erosion of the earth’s surface by moving water, ice, wind
or waves, leading to a reduction in elevation and in relief of landforms and of
landscapes.

Impact (effect)

Activity causing changes (effects) in the environment.An environmental effect is the
result of environmental impacts on human health and welfare. The term is also used
synonymously with environmental impact.5

Land cover (class)

The observed (bio)physical cover on the earth’s surface.6 Land cover indicates the
physical land type e.g. forest or open water.

Mitigation

Measures taken to avoid, reduce, or compensate for adverse environmental impacts
during project implementation.

Modified habitat

Areas where the natural habitat has been altered, often through the introduction of
alien species of plants and animals, such as in agricultural areas.

Natural forest

A forest composed of indigenous trees and not classified as forest plantation. Forest
typically refers to land with a tree canopy cover of more than 10 percent and area
of more than 0.5 ha.7 In this report, the term natural forest includes remnants of
degraded forest and shrub land.

Natural habitat

Land and water areas where the biological communities are formed largely by native
plant and animal species, and where human activity has not essentially modified the
area’s primary ecological functions.

Offset

Compensatory measures that aim to ensure that the project does not cause
significant net degradation to the environment. Such measures may relate to
conservation of habitat and biodiversity, preservation of ambient conditions, and
greenhouse gas emissions.

Movable or immovable objects, sites,
structures, groups of structures, and
natural features and landscapes that have
archaeological, paleontological, historical,
architectural, religious, aesthetic, or other
cultural significance.

Planted forests
(Plantation)

Planted forests are composed of trees
established through planting and/or
through deliberate seeding of native or
introduced species. Establishment is either
through afforestation on land which has not
carried forest within living memory or by
reforestation of previously forested land.8

Protected areas

Areas legally designated to protect or
conserve biodiversity, including areas
proposed by governments for such
designation.

Social forestry

Tree planting or natural forest management
designed to meet the forestry - related
basic needs of rural people9. It excludes
forestry which contributes to development
solely through employment and wages,
but includes activities by forestry industries
and public services to encourage and assist
forestry activities at a community level.

Threatened species

Any species which are vulnerable to
endangerment in the near future. The
International Union for Conservation
of Nature (IUCN)10 divides threatened
species into three categories: vulnerable
species; endangered species; and critically
endangered species.

Wildlife sanctuary

A naturally occurring sanctuary, such as an
island, that provides protection for species
from hunting, predation, competition or
poaching. A protected area, a geographic
territory within which wildlife is protected.11

Upazila

Geographical region in Bangladesh used for
administrative or other purposes. It functions
as a sub-unit of a district.

BACKGROUND AND OBJECTIVE
1 . 1 B A C K G R O U N D 12
Violence in Rakhine State, Myanmar, which began on 25th August 2017,
has driven an estimated 621,000 Rohingya across the border into Cox’s
Bazar, Bangladesh. The speed and scale of the influx has resulted in a critical
humanitarian emergency. The people who have arrived in Bangladesh since 25th
August 2017 are now reliant on humanitarian assistance for food, shelter, and
other life-saving needs. Basic services that were available prior to the influx are
under severe strain due to the massive increase in the number of people in the
area. In some of the sites that have spontaneously emerged, water and sanitation
facilities are limited or of poor quality, and extremely high population density
raises the risks of an outbreak of disease. The Rohingya population in Cox’s Bazar
is highly vulnerable, living in extremely difficult conditions after having fled
conflict. The figure below shows the estimated Rohingya population by location
(as of November 19th, 2017).
The Rohingya have been arriving in two upazilas, that of Ukhia and that of
Teknaf in the Cox’s Bazar district of Bangladesh13. The area of influx is bordered
on the north by the Ramu and Naikhongchhari upazila, by the Arakan state of
Myanmar on the east, and by the Bay of Bengal on the south and west. A base
map is provided in Figure 1-1 showing the Rohingya influx area. The population
of Rohingya by location is presented in Table 1-1.
Population movements within Cox’s Bazar remain highly fluid, with increasing
concentration in Ukhia, where the Government has allocated 3,000 acres (1,200
ha) for a new camp. People have begun arriving at the proposed site before
infrastructure and services can be established. Crucially, there is limited access to
the site and the construction of roads has just started, preventing the development
of infrastructure including water and sanitation facilities. In some sites, people are
constructing new shelters on any land they can find. Efforts by the Government of
Bangladesh and the local community are being complemented by UN agencies
This section follows the Situation Report: Rohingya Refugee Crisis. Cox’s Bazar / 19 November 2017, Inter sector
coordination group (www.humanitarianresponse.info/en/operations/bangladesh/document/situation-reportrohingya-crisis-coxs-bazar-19-november-2017).

12

The physical setting of the Rohingya influx area is presented in terms of geographical location, demography,
geography, bio-ecological settings and extent of services and facility providing institutions. Most of the demographic
and infrastructural statistics are captured from the census and district reports published by the Bangladesh Bureau of
Statistics in 2011 (BBS, 2013; BBS, 2014). Secondary literature sources are utilised extensively for the description of the
geology, bio-ecological regions and river network.

site planning and development. Camp
in Charge (CiC) officials are government
officials from Dhaka, designated by the
RRRC. They are the administrators of
the settlements, and responsible for the
coordination and delivery of services in
conjunction with the Bangladeshi Army.
The army is a key operating actor in the
settlements; it is responsible for safety and
security, the distribution of food and nonfood items (NFI), providing security at the
distribution points, and is involved in the
biometrical registration of all Rohingya.
There were several UN agencies (IOM,
UNFPA, UNHCR UNICEF, WFP and others)
as well as a number of national and
international NGOs providing assistance
to the Rohingya in Cox’s Bazar before this
latest influx, and their approach was to
complement humanitarian assistance
Creation date: 25 January 2018 | Source: ISCG, RRRC, Site Planning and Site Management
with support for host communities.
Sector The boundaries and names shown and the designations used on this map do not imply
official endorsement or acceptance by the United Nations
The local communities in Cox’s Bazar
have played host to a population of
approximately 35,000 Rohingya settled in camps
and NGOs who are scaling up their activities on
and an estimated 350,000 unregistered Rohingya
the ground in Cox’s Bazar, but a long-term plan for
for years. The new influx has placed a great strain
managing the situation has not yet been finalised.
on host communities and existing services. Despite
A good overview of the situation at the makeshift
this, local communities have been at the frontline
camps is presented in the recent publication “Life in
of the response, providing food and basic items for
the camps”14.
new arrivals. According to official census figures,
The Rohingya Refugee Repatriation Commissioner
the number of new Rohingya represents almost
(RRRC), under the Ministry of Disaster Management
a doubling of the population in the two suband Relief, is the government body in charge of the
districts (Ukhia and Teknaf ) which have received
Rohingya influx. The RRRC gives authorisations for
14

the largest number of people, and this will change
the demographic make-up of certain communities
drastically in terms of ethnicity and religion.
The Rohingya are officially not allowed to leave the
settlements. To that effect, checkpoints have been
established on the roads. The army checks vehicles
that leave the settlements, and requests passports
or national ID. This restricts Rohingya in their
freedom of movement from outside of their camp.
An important source of income for Rohingya is
the collection of fuelwood from the natural forests
and community forests. Rohingya, often women
and children, gather fuelwood in the forests
and sell it at local markets. Resources are shared
with host communities and tensions over firewood
collection are high.
The minimum World Health Organization (WHO)
requirement of water for personal use is 7.5—15 L

per person per day15. Cox’s Bazar is a dry area, low
on water resources. Groundwater from tube-wells is
the only potable water source, yet this water often
has elevated arsenic and salinity levels. Salinity is
worse in winter as saline water goes upward16. The
new influx of Rohingya has placed an additional
strain on scarce resources and WASH facilities are
not always proportionally allocated17. The quality
of drinking water is of high concern, as 83% of
samples tested at source and household level were
biologically contaminated.
Approximately 250 deep tube-wells have been
installed. Though deep aquifers exist, drilling for
deep wells is expensive. It is unclear what volume of
water they hold.
For camp-type settlements, a minimum area of
30m² per person should be available18, if communal
services can be provided by facilities outside of

the planned area. Communal facilities may include
markets, hospitals, cemeteries, water treatment
sites, and schools. If those communal services
do not exist, 45m² per person including housing
plots should be available. In the settlements,
high population density paired with a scarcity of
land complicates efforts to carry out effective site
management.
The Armed Forces Division (AFD) is constructing
a 22km access road, including bridges. The Rural
Electrification Board (REB) is currently working
on the installation of new light fixtures. After
distribution of emergency shelter kits (including
bamboo), the current focus is on shelter upgrades,
decongestion and improving living conditions in
the camps.

sufficient numbers of latrines, water points and
bathing facilities, and overall these facilities lack
basic protection measures including gender
segregation. Moreover, they are in locations not
easily accessible for women given gender mobility
restrictions21. To avoid open bathing and defecation,
women reportedly wash and defecate inside their
shelters, restrict food and water intake, and restrict
movement during their menstrual periods. This
poses severe hygiene and health risks for them.
Other women who have not been able to set up
facilities inside their homes report using the shared
facilities at night, hoping they cannot be easily seen;
they remain highly vulnerable to gender-based
violence and violence against women (GBVAW).

According to the most recent
family counting data19,
approximately 53% of the
Rohingya population are women
and girls, with the largest gender
discrepancy being among the
population of working age (1859) where 55% are female.
636,000 newcomers need
immediate access to water and
sanitation20. This increasing
population currently lacks
Balukhali makeshift camp

The Ministry of Disaster Management and Relief
(MoDMR) raised the following Key Questions:

Environmental problems associated with the influx
of asylum seekers have been well documented
over the years. In the absence of mitigating
measures, physical deterioration of the surrounding
environment soon takes place, in turn generating
other impacts on both the newcomers and on local
populations. Competition for natural resources such
as fuelwood, building materials, fresh water and
wild food may be an immediate concern.

• What is the monetary value of environmental
losses and damage caused by the Rohingya
influx?

Rohingya camps are situated near the protected
areas (PA) of Teknaf Wildlife Sanctuary (TWS), the
proposed Inani National Park and the Himchari
National Park. These areas have already suffered
degradation, and expansion of the camps is likely to
result in significant ecological impacts as forest and
agricultural land is converted to establish housing,
schools, water supply and sanitation facilities.

The influx area map is presented in Figure
1-2. A broad Area of Influence was selected to
accommodate the potential cumulative impacts of
the influx on the ecosystems in the region.

This assessment process was conducted in
constant communication with the Government of
Bangladesh, UN organizations, NGOs, and other key
stakeholders.
The Ministry of Environment and Forests (MoEF)
raised the following Key Questions that this study
has to address:
• What environmental impacts have been caused
by the Rohingya influx to date?
• What are the predicted environmental impacts if
the development continues?
• What is proposed to avoid, mitigate or offset the
environmental impacts?

20

• What feasible restoration projects may be
recommended to offset the environmental
damage?
• How much investment is required for restoration
of degraded ecosystem and implementation of
environmental management plan?

The following activities related to the influx may
cause environmental impacts:
• Land clearing for setting up the camps,
supporting facilities, infrastructure and services;
• Construction of shelters, supporting facilities and
roads;
• Construction and operation of water wells and
latrines;
• Solid waste generation and litter;
• Cooking with fuelwood, charcoal and/or
briquettes;
• Collection of fuelwood to support personal
cooking and for income generation;
• Illegal hunting, poaching and fishing;
• Transport operation to deliver goods and services
to the camps;
• Off-road movement of large groups of people.

APPROACH AND METHODOLOGY
This study is informed by environmental requirements included in UNDP’s
Social and Environmental Standards (SES),22 UNHCR’s Environmental Guidelines
(1996) and other national and international safeguards standards. It analyses
developments, both current and future. The following methodology was used to
address the study’s objectives:
• Desk review of available information such as maps and reports23. Preparation of
Rapid Environmental Assessment (REA) checklists24 for the collection of relevant
information (see Annexes A and B);
• Consultation with key stakeholders (Government of Bangladesh, UN agencies,
NGOs, local people and Rohingya see Annex C);
• Conducting a series of Key Informant Interviews (KII);
• Focus Group Discussions (FGD) with forestry and environmental stakeholders;
• Limited primary data collection on forest inventory in the remnants plantation
near to the Rohingya camps;
• Review of national policy, laws/regulations and procedures relating to
environment, occupational health and safety, resettlement and rehabilitation,
indigenous people, gender, etc.;
• Gathering of required environmental and socio-economic baseline information
on the Rohingya influx and settled areas;
• Prediction of environmental and ecological impacts to be generated for the
assessment and proposing of appropriate mitigation and restoration measures;
• Taking into account the benefits or positive impacts of an environmental
management plan and proposing habitat enhancement measures; and
• Proposing mitigation measures to improve the degraded environment (forests,
solid waste management, cooking fuel supply, water supply, etc.)

Overcrowding, creating risks for women and girls with regards to their safety,
security and vulnerability
Unhygienic living conditions inside shelters increasing health risks to women and
adolescent girls

Impact on human health from sanitation and management of solid waste and
chemicals

2.2 SIGNIFICANCE OF
I M PA C T S
Significance of impacts was determined using
UNDPâ&#x20AC;&#x2122;s Social and Environmental Screening
Procedure (2015). The level of significance of the
potential environmental risks includes both the
potential impact (e.g. consequences if the risk were
to occur) and probability (e.g. the likelihood of the
risk occurring) for each identified risk.
The following factors were considered when
estimating the potential impact:

the economic, social or cultural well-being of a large
number of people?
Manageability: Will relatively uncomplicated,
accepted measures suffice to avoid or mitigate the
potential impacts, or is a detailed study required to
understand if the impacts can be managed. If the
latter, which management measures are needed?
Duration: Will the adverse impacts be short-term (e.g.
exist only during construction), medium term (e.g. five
years) or long-term?
Reversibility: Is an impact reversible or irreversible?

Type and location: Is the project in a high-risk sector
or does it include high-risk components? Is it located
in a sensitive area? (e.g. in a densely populated area,
near critical habitats, indigenous territories, protected
areas, etc.)

Community Involvement: Absence of community
involvement is an inherent risk for the success and
sustainability of any project. Have project-affected
communities been consulted in project planning and
design? Will they have a substantive role to play in the
project going forward?

Magnitude or intensity: Could an impact result in
the destruction or serious impairment of a social or
environmental feature or system, or deterioration of

Both impact and probability were assessed on a
scale of 1 (low) to 5 (high) for each identified impact
(see Section 5).

Table 3-2 Rating the â&#x20AC;&#x2DC;Impactâ&#x20AC;&#x2122; of a Risk

Adverse impacts on people and/or environment of medium to large magnitude,
spatial extent and duration more limited than critical (e.g. predictable, mostly
temporary, reversible). The potential risk impacts of projects that may affect the
human rights, lands, natural resources, territories, and traditional livelihoods of
indigenous peoples are to be considered at a minimum potentially severe.

3

Moderate

Impacts of low magnitude, limited in scale (site-specific) and duration (temporary),
can be avoided, managed and/or mitigated with relatively uncomplicated and
acceptable measures.

2

Minor

Very limited impacts in terms of magnitude (e.g. small affected area, very low
number of people affected) and duration (short), may be easily avoided, managed
or mitigated.

1

Negligible

Negligible or no adverse impacts on communities, individuals, and/or
environment.

Rating the ‘Probability’ of a Risk

Determining ‘Significance’ of Risk

Rating

5

R

R

R

R

R

5

Expected

4

Y

Y

R

R

R

4

Highly Likely
Moderately likely

3

G

Y

3

Y

Y

Y

2

Not Likely

2

G

G

Y

Y

Y

1

Slight

1

G

G

G

G

G

Impact

Score

1

2 . 3 C U M U L AT I V E
I M PA C T S
As discussed further in Section 5, the physical
impacts of the Rohingya influx do not have a
cumulative potential. Therefore, the Area of
Influence (AoI) for the physical impacts of the
Rohingya influx is limited to the direct footprint of
the camps and the small buffer area around them.
For impacts on ecosystems, where potential exists
for cumulative impacts, the study was conducted

2

3

4

5

Probability
Green = Low, Yellow = Moderate, Red = High

in a broader AoI to ensure inclusion of the relevant
sources and receptors of the impacts. The AoI for
the impacts on ecosystems encompasses the south
part of the Cox’s Bazar District (south of Ukhia) (see
Figure 1-1).

25

REGULATORY REQUIREMENTS
AND INSTITUTIONS
3 . 1 N AT I O N A L
The Constitution of the Peoplesâ&#x20AC;&#x2122; Republic of Bangladesh, 1972
Article 18A, (15Th Amendment, 2012): The state shall endeavour to protect and
improve the environment and preserve and safeguard the natural resources,
biodiversity, wetlands, forest and wildlife for the present and future citizens.
Article 31: Right to Life has been extended to include right to safe environment
when the importation of radiated milk was challenged through a writ petition,
WP No. 92/1996.

National Environmental Policy 1992
The Bangladesh National Environmental Policy (GoB, 1992) sets out the basic
framework for environmental action together with a set of broad sectoral action
guidelines.

National Water Policy, 1999
Recognizes that poor water quality results in watershed degradation and
deforestation, reduction of biodiversity, wetland loss and coastal zone habitat
loss. Relevant policy includes ensuring adequate upland flow in water channels
to preserve the coastal estuary ecosystem threatened by the intrusion of salinity
from the sea.

The Coastal Zone Policy, 2005
This is a policy of integrated management of the coastal zone through the
agreement of different Ministries, Departments and Agencies to harmonise and
coordinate their activities in the coastal zone.
Based on the CZPo, a Coastal Development Strategy to harmonise the
sectoral policies of relevant Ministries and provide an integrated coastal zone
management framework for all development work in the coastal zone, was
approved in February 2006.

National Tourism Policy, 1992
The main objectives of the National Tourism Policy (1992) are: to create interest
in tourism among the national population; to preserve, protect, develop and

maintain tourism resources; to alleviate poverty
through job creation; and to build a positive image
of the country abroad.

Environment Conservation Act 1995 (ECA 1995)
The Environmental Conservation Act, 1995 (ECA â&#x20AC;&#x2DC;95)
is currently the main legislative document relating
to environmental protection in Bangladesh. The
main objectives of ECA â&#x20AC;&#x2DC;95 are: the conservation
and enhancement of the environment; and the
control and mitigation of environmental pollution.
The main strategies of the act include: the
declaration of ecologically critical areas, and
restriction on operations and processes, which can
or may not be carried out or initiated in them; a ban
on hill cutting; and regulation in respect of vehicles
emitting smoke causing environmental harm.

Environment Conservation Rules, 1997
(subsequent amendments in 2002 and 2003)
A set of relevant rules to implement the ECAâ&#x20AC;&#x2122; 95 was
made public in August 1997.
Standards in Bangladesh in general are less
stringent than those in developed countries. This
is with a view to promoting and encouraging
industrialisation in the country.

Environment Court Act, 2000 (Amended 2002)
Provides for the establishment of one or more
Environment Courts, initially in every division of the
country, with specific terms of reference to deal with
environmental offences (under the Environment
Conservation Act, or any other law specified in the
Official Gazette and the rules made under those laws).

Antiquities Act (1968)
Ensures that antiquities of historical,
anthropological, religious, military or scientific
interest are protected.

Forest Act, 1927 (Amended 1990,2000)
Empowers the Government to declare any area of
forest as reserve and in doing so allows it to take
measures for in-situ conservation of biological
diversity.

Wildlife (Preservation) Order, 1973 & Wildlife
(Preservation) (Amendment) Act, 1974 and
Wildlife Preservation and Security Act, 2012
Provides for the protection of wildlife as well as
their habitat. It defines various protected areas
in the form of game reserves, national parks and
wildlife sanctuaries and aims to preserve wildlife in
those protected areas.

Marine Fisheries Ordinance (1983) & Marine
Fisheries Rules (1983)
Makes provisions for the management, conservation
and development of the marine fisheries of Bangladesh.

National Biodiversity Act, 2017
Regulates biodiversity conservation and sustainable
use of its resources, biota and the fair and equitable
share of the benefits derived from their use, as well
as other matters.

Ecologically Critical Area Act (2016)
Sets forth the activities that are permitted in
ecologically critical areas, and those that are not.

27

3 . 2 I N T E R N AT I O N A L
Ramsar Convention on Wetlands of
International Importance Especially
Waterfowl Habitat (2 February 1971), as
amended
Provides the intergovernmental framework for
international co-operation for the conservation and
wise use of wetland habitat and species.

The Convention of Biological Diversity (1992)
Requires each signatory nation to develop
national strategies, plans or programmes for the
conservation and sustainable use of biological
diversity.

Convention Concerning the Protection of
World Cultural and Natural Heritage (Paris, 12
November, 1972)
Protects cultural monuments and natural sites
within their territory that are recognised to be
of such outstanding universal value that their
safeguarding concerns humanity as a whole.
Convention on International Trade in Endangered
Species in Wild Fauna and Flora (Washington, 3
March 1973)
Ensures, through international co-operation, that
the international trade in specimens of species
of wild fauna and flora does not threaten the
conservation status of the species concerned.

Bonn Convention on the Conservation of
Migratory Species of Wild Animals (Bonn, 23
June 1979)
Conserves migratory species by Parties restricting
harvests, conserving habitat and controlling other
adverse factors. Sustainable utilisation is an implicit
goal.

28

co-operation between producing and consuming
member states in the tropical timber industry.

International Laws related to EIA
Convention on Environmental Impact Assessment
in a Transboundary Context (Espoo, 1991):
This is the first multi-lateral EIA treaty. It entered into
force in 1997 and looks at EIA in a transboundary
context. The Espoo Convention sets out the obligations
of Parties to assess the environmental impact of certain
activities at an early stage of planning.
Rio Declaration (1992):
Principle 17 of the Rio Declaration on Environment
and Development calls for the use of EIA as a
national decision-making instrument.
The other principle (15) of this declaration that is
relevant to EIA practice is the application of the
precautionary principle.
Agenda 21, which was also as a result of this
convention, proposes that governments should:
a. Develop, improve and apply environmental
impact assessment to foster sustainable
industrial development (9.18); and
b. Introduce appropriate EIA procedures for
proposed projects likely to have significant
impacts upon biological diversity, providing for
suitable information to be made widely available
and for public participation, where appropriate,
and encouraging the assessment of impacts of
relevant policies and programmes on biological
diversity.
The UNECE (Aarhus) Convention on Access to
Information, Public Participation in Decision Making
and Access to Justice in Environmental Matters
(1998) covers decisions at the level of projects and
plans, programmes and policies and by extension,
applies to EIA and SEA.

3 . 3 PA R T N E R
REQUIREMENTS

The International Tropical Timber Agreement
(Geneva, 18 November 1983)

in its programmes and projects to support
sustainable development; strengthen its efforts
to attain socially and environmentally beneficial
development outcomes; and present an integrated
framework for achieving a consistent level of
quality in UNDP’s programming.

Asian Development Bank (ADB)’s Safeguard
Policy Statement, 2009
ADB affirms that environmental and social
sustainability is a cornerstone of economic
growth and poverty reduction in Asia and the
Pacific. ADB’s Strategy 2020 emphasises assisting
Developing Member Countries (DMCs) to pursue
environmentally sustainable and inclusive
economic growth. In addition, ADB is committed
to ensuring the social and environmental
sustainability of the projects it supports.

World Bank’s Environmental and Social
Management Framework (ESMF), June 2011
The Environmental and Social Management
Framework (ESMF) provides general policies,
guidelines, codes of practice and procedures to be
integrated into the implementation of the World
Bank-supported Project.

3.4 INSTITUTIONAL
ARRANGEMENTS
Ministry of Environment and Forests (MoEF)
The role of the MoEF is to ensure a sustainable
environment and optimum forest coverage.

Department of Environment (DoE)
The role of the DoE is to help secure a clean and
healthy environment for the benefit of present and
future generations through: the fair and consistent
application of environmental rules and regulations;
guiding, training and promoting awareness of
environmental issues; and sustainable action on
critical environmental problems that demonstrate

practical solutions, and that galvanise public
support and involvement.

Forest Department (FD)
Responsible for the conservation and expansion
of forest and its biodiversity and socio-economic
development through modern technology and
innovation.

Bangladesh Forest Research Institute (BRFI)
Aims to maintain the sustainable productivity of
forest land and forest industries without resource
depletion.It provides research support to the FD,
BFIDC, end-users and others engaged in forestry
activities.

Ministry of Disaster Management and Relief
(MoDMR)
The mandate of the MoDMR is to drive national
risk reduction reform programmes. Its mission in
relation to this agenda is: ‘To achieve a paradigm
shift in disaster management from conventional
response and relief to a more comprehensive risk
reduction culture, and to promote food security as
an important factor in ensuring the resilience of
communities to hazards.’

Department of Disaster Management
The disaster management vision of the
Government of Bangladesh is to reduce the risk of
people, especially the poor and the disadvantaged,
from the effects of natural, environmental and
human induced hazards, to a humanitarian level
that is manageable and acceptable, and to have
in place an efficient emergency response system
capable of handling large scale disasters.
Cyclone Preparedness Programme (CPP)
CPP is active in the field of disaster management
in Bangladesh especially in early warning systems,
search and rescue, evacuation, sheltering, first aid,
relief distribution and rehabilitation activities.

29

BASELINE CONDITIONS

4.1 RESOURCE USE
Both deforestation and reforestation have shaped the present condition of
the Teknaf peninsula. As part of the programme of afforestation of newly
accredited and acquired lands in coastal areas beginning in the late 1960s, the
Forest Department widely planted hundreds of hectares of coastal forest. A
forest management policy later allowed for the conversion of natural forest into
plantations. Deforestation and forest degradation have taken place concurrently
as forest resource extraction has become a secondary occupation for coastal
households. These practices have not only decimated wildlife habitats, but have
aslo changed plant species composition and have been responsible for ecosystem
degradation in the region.
Hill cutting, usually for filling in low lying areas, has occurred throughout the Teknaf
peninsula since the early 1970s. Population pressure, including the influx of a total
of 240,000 Rohingya from Myanmar in the early 1970s and again in the early 1990s,
has seen the large-scale conversion of forest as well as agricultural land for human
settlement purposes. This has had a severe impact on flora and fauna species and
habitats. The construction of shelters for the Rohingya built in the forest areas of
Teknaf peninsula has contributed to forest degradation and deforestation.
Historically, the main uses of the land of the region were small scale agricultural
crop production, betel nut/leaf cultivation and another homestead agroforestry.
Along with settlement, the clearing of the native vegetation has had one of
the greatest impacts on the natural reserve forests in this region. Currently, the
main use of the land includes site for the construction of hotels and resorts, the
development of urban and tourism facilities, agriculture, aquaculture and salt
farming, human settlement, shrimp hatcheries, fishing and dry fish processing.
The Naf river estuary once supported extensive mangroves on its tidal floodplain
areas, but almost the entire area of mangrove has been converted for agricultural
use. In the 1990s around 30% of the land was used for crop production. According
to GIS records, agricultural land covered 7202 ha in 199925.

The region, now a degraded forest land, includes
three Ecologically Critical Areas (ECAs)–the western,
coastal zone of Teknaf Peninsula, St Martin’s Island,
and Sonadia Island, and two Protected Areas (PA)–
the Himchari National Park and the Teknaf Wildlife
Sanctuary (TWS). The Inani National Park, proposed
as a protected area but not officially established as
one, is considered a key biodiversity area and should
be treated as a critical habitat. An overview map of
the protected areas is presented in Figure 4-5.
The region is rich in biodiversity with numerous
environmental assets and scenic beauty. It has various
tourist attractions, its most attractive feature being a
picturesque beach which is the longest uninterrupted
stretch of beach in the world. The sea beach also
supports five species of sea turtles–the olive ridley
turtle (Lepidochelys olivacea), the green turtle
(Chelonia mydas), the hawksbill turtle (Eretmochelys
imbricate), the loggerhead turtle (Caretta caretta),
and the leather back turtle (Dermochelys coriacea).
Mudflats and sand dunes across the sea beach are the
area’s other two environmental assets. The Ipomoea
pes-caprae dominated sand dune vegetation in the
shore line of Cox’s Bazar through Teknaf protects the
beach from soil erosion, increases the elevation of
the beach and supports the breeding of the turtles.
There is a significant area of sea-beach found to be
planted by Jhau (Casuarina equisetifolia) and Baen
(Avicennia officinalis) tree in the Cox’s Bazar zone. A
large size sand dune formation due to this plantation
was observed.

On the other side, the hilly range runs from Cox’s
Bazar to Teknaf. The Cox’s Bazar-Teknaf peninsula
forms part of the East Asian Australasian and the
Central Asian flyway. The Teknaf Wildlife Sanctuary
(TWS), one of the few places in Bangladesh where
elephants can be seen in the wild, is at one end of
the influx area.
The habitat of these environmental assets and
biodiversity has a very fragile ecosystem. Surface
and ground water availability is limited and the
saline water on both sides of the influx area can
only support a few crops and trees. Local people are
dependent on small water streams originating from
the hills/terrains in the area.

Social forest plantation near TWS

|

Photo: UNDP Bangladesh/Arif Faisal

31

assets, and adversely impact lives and livelihoods,
especially those of poor people. Climate change
will exacerbate many of the current problems and
natural hazards the country faces and the predicted
higher wind speeds and storm surges will lead to
more damage in the coastal region. Predictions
include: increasingly frequent and severe tropical
cyclones; heavier/lighter and more erratic rainfall;
higher river flows; river bank and coastal erosion;
increased sedimentation; melting of the Himalayan
glaciers; and sea level rises.
Betel leaf garden near TWS

|

Photo: SDC/A. Egli

4 . 2 C L I M AT E
The climate of this region is tropical and
characterised by a change of four, monsoon-related
seasons: pre-monsoon (March to May); monsoon
(June to September); post-monsoon (October
to November); and the dry season (December to
February). The influx area is highly susceptible
to tropical cyclones and tidal surges. Cyclone
storms develop in the Bay, generally in the periods
from April to May and October to November,
occasionally making landfall and causing severe
damage to human settlements and vegetation.
Bangladesh is widely recognised as one of the
most climate-vulnerable countries in the world. It
experiences frequent natural disasters, which cause
loss of life, damage to infrastructure and economic

4 . 3 N AT U R A L D I S A S T E R S
Bangladesh is vulnerable to floods, flash floods,
salinity, storm surges, landslides and earthquakes.
Flooding, mainly in the period from May to October,
occurs almost annually and affects most of the
country with the exception of Barind Tract and hilly
areas. The western part of the country, including
Barind Tract, is a drought prone area which
faces severe problems due to a scarcity of water,
particularly during the dry season. The southern
coastal part of Bangladesh is prone to storm surges
and soil salinity while the hilly areas of Bangladesh
(Chittagong Hill Tracts, Coxâ&#x20AC;&#x2122;s Bazar and Teknaf ) are
vulnerable to landslides26.
The area of the Rohingya influx has a history of
occurrence of landslides, earthquakes, flash floods
and tidal surges. Although the main area of the
Rohingya camps is located outside of the flood
zone, the camps are vulnerable to extreme weather
events such as cyclones and have to withstand
major precipitation and strong winds. The steep
slopes may become unstable in the monsoon
seasons and cause landslides, shelter damage and
other destruction.
In general, neither the structures in the Rohingya
camps nor those in the makeshift settlements are
able to withstand cyclones or floods; nearly 70% of
shelters in settlements were damaged by Cyclone
Mora in May 201727.

4.4 AIR QUALIT Y
Baseline data on air quality is currently not
available. However, the area of influx is hilly and
close to the sea, and this geographical location,
coupled with the limited amount of industry in
the area, means that air quality remains within
acceptable limits. Pollution from cars may be a
factor in the future; there is relatively heavy tourist
traffic from Cox’s Bazar to Teknaf.

4 . 5 S U R FA C E A N D
G R O U N D WAT E R
Surface water
The Moheshkhali Channel, Baak Khali and Naf rivers
and Bay of Bengal are the main waterways of the
region. The Moheshkhali Channel flows into the
Bay of Bengal near Cox’s Bazar and passes the north
western boundary of the AoI. The Bakkhali River
originates from the Chittagong Hill Tracts and flows
into the Bay near Cox’s Bazar. Five other canals run
through the hilly hinterland. They are: the Reju,
Inani, Mankhali, Rajachora and Mathabanga canals.
During winter, the canals become almost dry.
Because of the scarcity of fresh water, the region is
dependent on ground water sources for its crops
and horticulture. Watersheds are presented in
Figure 4-1.

Ground water systems
Bangladesh is considered rich in ground water
resources. Ground water resources are determined
by properties of ground water storage reservoirs
and volumes of annual recharge. Figure 4-2 below
is the ground water zoning map of Bangladesh,
2010. From the map, it can be seen that the ground
water level in and around the influx area is shallow.
Ground water storage reservoirs are composed
of three aquifers in Bangladesh. They are: the
upper aquifer or composite aquifer, the main
aquifer (at a depth of 6 m to 100 m) and the deep
aquifer. With the increased trend of urbanisation
and irregular rainfall patterns, surface run-off

has increased in recent times and this is likely
to further reduce ground water recharge in all
aquifers in the influx area. It is evident from the
map that the transmission of the main aquifer is
good to excellent over most of the country but it is
deteriorating towards the south and the east. In the
areas near the coast the water table is descending
due to over exploitation.

4.6 SOILS AND TERRAIN
Soils
The major soil types are red, alluvial, muddy and
sandy soil. The soils of the Dupitila formations
were formed on unconsolidated and compact
rocks, moderately well to excessively drained and
probably the oldest of the area28.
The soils range from clay to clayey loam on level
ground and from sandy loam to coarse sand on
hilly land. In the forest areas, the clayey and sandy
loams are fertile, and the sandy soil is often infused
with iron, resulting in a red or yellowish tinge. The
hilly soils developed from un-consolidated rocks
are moderately well to excessively well drained,
generally deep, and probably the oldest soils in
this region, while those occurring on hills from
consolidated rocks tend to be formed in weathered
sandstones, shales, and siltstones29. The soils
developing from the weathered sandstones tend to
be sandy loams to clay loams, and those in shales
silty clay loams. Generally, the soils of Tipam Surma
formations are less acidic in reaction relative to the
soils of Dupitila formations30.

Geomorphology
Bangladesh is relatively young and situated in a
low-lying area with three main geomorphological
regions, plain terraces and hills. Most of the area of
Bangladesh is a vast low lying alluvial plain, sloping
gently to the south and southeast. According to the
Ecological Zoning Map of Bangladesh, the influx
area falls under the Chittagong Coastal Plain and in
terms of physiological formation, the area has lower

hill ranges. The area also has one of the worldâ&#x20AC;&#x2122;s
longest uninterrupted natural sandy sea beaches;
the beach in Coxâ&#x20AC;&#x2122;s Bazar is an unbroken 125 km
sandy sea beach with a gentle slope. The influx
area is situated on a combination of small hills and
Figure 4-1 Watersheds in the AoI

34

plains extending into the Chittagong Hill Tracts
bordering Myanmar. This region has a complicated
and relatively recent tectonic history, including a
succession of anticlines and synclines of tertiary
rock with a NW-SE axis and local separation by a

complex of alluvial plains and Pliocene and recent
alluvial deposits. The quaternary of the coastal
plain is a complex of various sediments of old sand
beach, old calcareous corals, silty clay, acid-sulphate

clays and alluvial deposits. The area is used for
agriculture and is largely a complex of alluviums,
terraces and old terrace fans with unconsolidated
sediments of sand, sandy loam and loamy clay.

Figure 4-2 Ground water zoning map of Bangladesh

35

4 . 7 V E G E TAT I O N A N D
WILDLIFE
The forest land in the Ukhia and Teknaf upazilas is
covered by tropical evergreen and semi-evergreen
forests dominated by Garjan (Dipterocarpus spp.)
occurring in deep valleys and shaded slopes31.
Human activities have denuded most parts of the
hills which have been re-occupied by sungrass, herbs
and shrubs. Still, the area houses rich biodiversity,
especially within the protected areas (PA).
In the last two decades, the forest areas in Ukhia
and Teknaf have been significantly degraded or
have been cleared. Between 1989 and 2009, the
forest coverage of TWS was reduced by 46% from
3,304 ha to 1,794 ha. The shrub type of forests
increased by 25% from 6,263 ha to 7,824 ha32.
Land cover classes of the AoI (as of 2015) are

presented in Figure 4-3 and described in Table 4- 1.
Figure 4-3 also indicates an outline of the footprint
of Rohingya camps (as of 8th November, 2017). The
diagram of land cover class areas is presented in
Figure 4-4.
Apart from the degradation, this forest area still
houses rich biodiversity including megafauna like
the Asian elephant (Elephas maximus) and many
different bird species. It has been confirmed that
more than 50% of the country’s wildlife species
are living in the forests of Ukhia, Teknaf, Inani
and Himchari within the Cox’s Bazar South Forest
Division.
A more detailed description of the protected area
is presented below and an overview map of the
protected areas located in the Cox’s Bazar District is
presented in Figure 4-3.

Table 4-1 Land Cover Classes in the Area of Influence (AoI)33
Land Cover Class

Teknaf Wildlife Sanctuary36
The Teknaf Wildlife Sanctuary
(TWS) is the most important forest
ecosystem in Bangladesh.
The sanctuary is home to the Teknaf
Game Reserve which was established
to focus on the conservation of
the Asian Elephant, more than
one hundred of which have been
observed in the sanctuary.37 In many
places, the elephant corridors have
been blocked by host communities
and infrastructure and some of these
corridors are being hampered by the
Rohingya population (see Figure 5-3).
Over the last 50 years. the vegetation
in the AoI has been degraded by
both human and natural factors.
In the period 1920 to 1990, natural
forests were cleared to make way
for wood lots. The Rohingya influx
in 1991 and several other influxes
reduced the forests of Ukhia and
Teknaf substantially. Three major
cyclones, in 1991, 1994 and 1997
severely affected the forest areas38.
Conversion of many foothills and
low-lying areas into paddy fields and
settlements through the process of

Figure 4-4 Land Cover Class Areas in the AoI

35

The map is provided by FAO Bangladesh. Certain non forest classes were aggregated in the report.

forest land encroachment has shrunk the forests
severely. Inside the TWS boundary, the settlements
and homestead forests were increased by 52.6%39.
In 2012, the natural forests under the TWS covered
only 10% of the area and the rest was covered by
shrubs with a few scattered trees.
The Nishorgo Support Project (2006) describes
eight habitats in the TWS which support rich
biodiversity. They are: high forests; plantations;

grasslands and bamboo; wetlands; tidal mudflats
and mangrove vegetation along the Naf River to
the east; sandy beaches along the Bay of Bengal
to the west; cliffs and steep slopes; and cultivated
fields and settlements.
Some of these habitats have been highly degraded
due to anthropogenic causes. Biodiversity in the TWS
covers many endangered species in Bangladesh40
and the habitat has been declared critical.41

Figure 4-5 Protected areas in the Cox’s Bazar District

In the 1990s the TWS housed more
than half of the mammalian species
of the country42. Since then, during
the last three decades, this area has
lost several faunal species due to
anthropogenic pressure.

Himchari National Park
Himchari National Park, declared in
1980, is one of the most important
protected areas in Bangladesh. It lies
within the Cox’s Bazar South Forest
Division covering an area of 1729
ha. The park is home to 56 species of
reptiles, 13 species of amphibians,
286 species of birds, and more than
100 species of trees, shrubs, grasses,
canes, palms, ferns and herbs. The
biodiversity of the park is threatened
by many anthropogenic factors
which have been exacerbated by
the Rohingya influx as merchants
illegally collect bamboo and
fuelwoods from this forest and sell
them to the Rohingya community.

IPAC. 2011. Land Use Change Trend Analysis in Seven Protected Areas in Bangladesh Under IPAC Through Application of Landsat Imageries. Dhaka,
Integrated Protected Area Co-management (IPAC)

Inani National Park
The Inani National Park, within the Coxâ&#x20AC;&#x2122;s Bazar
South Forest Division, covers an area of 7,700 ha of
reserve forest falling under an evergreen and semievergreen tropical forest zone. It includes both
the Inani and the Ukhia forest range. Although the
Inani forest area was historically rich in biodiversity,
the current vegetation consists mainly of herbs,
sungrass, shrubs and bushes. The high forest has
shrunk from 70% to less than 30% in the last three
decades.43 Bushes, sungrass and bamboo dominate
the landscape. There are 443 plant species from 93
families in the Inani National Park. A gymnospermic
tree species, Banspata (Podocarpus nerifolia), is one
of the rare trees still found in this forest. Among
the plant species, 140 (32% of the total) are herbs,
85 (19%) are shrubs, 151 (34%) are trees, 60 (13%)
are climbers and seven (2%) are epiphytes. This
forest is home to 29 species of amphibians under
six families. Among the amphibians, 12 are rare, 9
are common and 8 are very common. They belong
to 58 species of reptiles of which 5 are turtles and
tortoises (9%), 21 are lizards (36%), and 32 are
snakes (55%). The Arannayak Foundation44 has
confirmed that 34 reptiles (60%) found in the forest
are rare, 18 (31%) are common and 6 (10%) are
very common. It supports 253 species of bird of
which 195 are residents (77%) and the remaining 58
are migratory (23%). Among the birds, 44 species
(23%) are very rare, and 68 (35%) are rare. A total
of 39 mammals are found in this forest. Among the
mammals, 12 are carnivores, 11 are rodents, 7 are
bats and 4 are primates. 61% of the total mammals
of this forest belong to either rare or very rare
species (Arannayk Foundation 2016). Although the
current Rohingya influx does not have any direct
influence on the Inani protected area, there are still
some assumptions that bamboo and fuelwood are
being extracted from the Inani protected areas and
sold to the Rohingya community.

4.8 MARINE AND FRESH
WAT E R E N V I R O N M E N T
The surface hydrology in the forest areas is
regulated by rainfall and runoff from adjacent
uplands and the relief pattern of the plains. The
area is interspersed by valleys and gullies and
crossed by 149 streams which at the eastern side
flow to the Naf river and at the western side flow
to the Bay of Bengal45. Some streams have been
observed to be seasonal, drying up in the dry
season. There are a few shallow depressions in the
area providing wetlands to migratory birds, and fish
for local livelihoods. They also house habitats for
other wildlife.
A survey of the Fisheries fauna of the Naaf river
estuary in the 1990s recorded46 123 fish species, 20
species of shrimp and prawns, 3 species of crabs
and 2 species of lobster. The dominant group was
represented by a few small sized fishes. Given the
close proximity to the sea and the presence of
backwaters, the people in the region are habituated
in pisciculture and prawn culture. The people also
practice salt farming.

4 . 9 P H Y S I C A L C U LT U R A L
RESOURCES AND
TOURISM
The area of influence (AoI) is archaeologically rich,
prominent as a tourist spot, and popular for its
beautiful beaches.

4 . 1 0 C U R R E N T S TAT E O F
ENVIRONMENT AFTER
R O H I N G YA I N F L U X
In most parts of Ukhia, especially in the areas of
Kutupalong and Balukhali, land use has completely
changed within a short period of time. Some of the
hills have been completely denuded and deforested

and the area is now filled with shelters. Other hills
will likely face a similar fate. There are over a million
Rohingya who have so far been sheltered within a
few square kilometers of the influx area combining
old and new makeshift camps. A set of historical
satellite photos presented in Figure 4-6 demonstrates
forest degradation and changes in land-use caused
by makeshift camps.
The most alarming impacts of the influx are: forest
degradation and habitat loss; the fragmentation of
territory for wildlife; human-wildlife conflicts, hill
cutting, soil erosion and stream congestion; ground
water source depletion; watershed degradation and
water scarcity. Soil pollution and compaction, lighting,

noise and air pollution are other areas of concern.

Forest Degradation and Habitat Loss
The Rohingya gather whatever materials they
are able to in order to build their shelters. This
has resulted in indiscriminate cleaning of the
vegetation cover from hills and forests.
Fuelwood for daily cooking is also being collected
from forests, and this is causing serious forest
degradation and habitat destruction (see Section
5.2.1). A new access road to the Rohingya camps
on the Cox’s Bazar – Teknaf highway is under
construction and this will facilitate access not only
to the camps, but also to the forests and their
resources.

Hill Cutting, Soil Erosion and Stream
Congestion
To accommodate large numbers of Rohingya
people, a number of hills have been cleaned and
cut indiscriminately, and shelters have been set up
on the hills. Steps have been cut into the slope to
facilitate access to the shelters.

Typical fuel wood

|

Photo: SDC/A. Egli

Fragmentation of Wildlife’s Territory and
Corridor
The area from TWS to the Himchari National Park
is almost a continuous hill belt covered with
degraded forest vegetation. This allows wildlife,
especially the Asian elephant, to move freely
from one side to the other in search of food. The
elephant’s habitat and corridors have become
fragmented as a result of Rohingya settlement
inside the forest.

Human-Wildlife Conflicts
The Teknaf-Ukhia forest area is a habitat
comparatively rich in wildlife, where wild elephants,
deer, wild boar, monkeys, birds, squirrels, red
jungle fowl and different types of snakes still exist.
The construction of Rohingya shelters inside this
territory means that people and wildlife are now
cohabiting.
During the movement of both wildlife and humans,
there is high possibility of incidents of humanwildlife conflict; wildlife is at risk of being hunted
and killed, and people are also at risk. There are
reportedly incidents of deer hunting by Rohingya
for meat, and some Rohingya have been killed by
wild elephants48. In addition, local poachers may
seek to exploit the situation.

Hill cutting loosens the soil and can result in soil
erosion, sedimentation and siltation - a washing
out of the valuable fertile top soil that will make
the hills unsuitable for supporting any valuable
vegetation cover. The eroded soil will also cause
stream congestion, which might hinder stream
flow, which in turn will result in habitat loss, water
pollution and water scarcity further downstream.
Hill cutting and the clearing of vegetation cover
also increases the risk of hill and land slide at the
time of monsoon rains. Denuded hills become dry
and usually generate cracks, and in the rainy season
there is more chance that water will enter into
the denuded hills through the cracks. As a result,
there is a high risk of local landslides which could
cause the destruction of the shelters and potential
causalities (see the land slide risk map of the
Kutapalong makeshift camp49).

Watershed Degradation and Water Scarcity
Around 3,000 to 4,000 acres (1,200 – 1,600 ha) of
hilly land in the Teknaf-Ukhia-Himchari watershed
area have been cleared by removing vegetation
cover to erect shelters for the Rohingya people. The
watershed absorbs large quantities of rainwater,
and holds water with the help of the vegetation
cover existing on it; removing the vegetation cover
of hills reduces their water retaining capacities. This
capacity is already much reduced by the felling of
large trees.
The watershed acts as a major source of essential
fresh water in the form of a stream for local
residents; it is used for drinking and other domestic

purposes year-round. Fresh water scarcity is
now a common phenomenon in the TeknafUkhia areas, as most of the area is hilly, and its
subsoil is rocky and impermeable, restricting
boring for ground water.

Soil Pollution and Compaction
Polythene50 sheets, synthetic ropes and nails
are currently being used to make shelters for
the Rohingya, and these are a source of soil
pollution. Other sources of pollution are: plastic
bags used for packaging relief items; polythene
bags used for the distribution of cooked food
for children and newcomers; plastic bottles,
and used torch batteries. A proper system
of waste disposal needs to be in place for
these materials. Drainage systems blocked by
polythene bags have been identified as a major
cause of flooding in Bangladesh during the
monsoon season.

Lighting and Noise Pollution
Lighting in shelters at night, and cooking inside
the forest is hampering the nesting, roosting,
breeding, and feeding grounds of wildlife.
Noise, originating from communication among
the Rohingya people, service providers, relief
distributors, and from a sharp increase in
vehicular movement is also disturbing wildlife.

Air and Water Pollution
Smoke and dust generated from stoves and
from traffic is a source of air pollution. A lack
of solid waste management in the Rohingya
camps is causing water pollution in nearby
streams; unmanaged human waste is being
channeled to hilly streams and contaminating
water, which might cause the spread of
waterborne and contagious diseases among
nearby localities and host communities.

Polyethylene is a non-biodegradable, organic chemical compound
found in common products such as polythene bags, plastic furniture
and kitchen materials.

5.1.1 Ground Water
The Teknaf peninsula coastal zone has limited ground water storage. This was
not an issue when there were less people living in the area but the demand has
increased manifold since the August influx and thousands of shallow tube wells
have been dug in the influx area at different slopes very close to each other,
particularly in the Kutupalong and Balukhali makeshift camps to accommodate
the Rohingya. This has resulted in excessive withdrawals of water from the
shallow aquifer and a drying up of some of the wells.
There are concerns that the shallow aquifer could be exhausted within several
months. The water sector service providers are looking for deep wells, but there
is no certainty yet regarding their availability.
The emergency situation has meant that no proper thought has gone into an
appropriate location for or design of latrines. Thousands of latrines without
proper soak pits have been installed along the contour lines of the hills close
to the shelters and very close to water points. The ongoing arrival of Rohingya
to the area has resulted in an increase in the population at multiple sites and
an increased burden on existing facilities. Leakage, seepage and overflow from
these facilities are being reported, causing ground water contamination. Large
numbers of nonfunctional latrines and tube wells need to be decommissioned
and repaired to reduce the public health risk.
Results of ground water samples from different camps (Kutupalong and
Balukhali) for the E-coli test by the Emergency Response Unit of the International
Red Cross portray an alarming picture. About 70% of the samples were observed
to be heavily polluted.51
Red Cross. Emergency response unit. Lab report. IFRC ERU M40 lab tests on the water from 135 wells across the
Balikahli 02, Hakimpara and Burma Para settlements. 28.9.2017 â&#x20AC;&#x201C; 7.11.2017

With the assistance of Chittagong Regional Laboratory of the Department of Environment (DoE), this
studyâ&#x20AC;&#x2122;s team conducted tests on some physical-chemical parameters including arsenic, iron, chloride
and salinity. Test results revealed that levels of arsenic were within acceptable levels but iron content was
relatively high. (Appendix D). Test results of the Emergency Response Unit of the International Red Cross
also confirm the findings on arsenic by the DoE.

Latrine on the top of the hill |

Photo: UNDP Bangladesh/A. Chaikine

Latrine under the eroded hill slope

|

Photo: UNDP Bangladesh/Arif Faisal

Water well in Kutupalong camp

Indoor cooking

|

|

Photo A.Chaikine, UNDP

Photo: UNDP Bangladesh/Arif Faisal

45

5.1.2 Surface Water
With the exception of some small streams, the
influx area has limited sources of surface water.
Main water sources such as the Naf River and
other big channels are at some distance and are
saline and brackish especially in the lower part of
the rivers. Fresh water sources are basically pond
water and a few small streams originating from the
hills. These ponds and streams are not capable of
meeting the water needs of the population of the
makeshift camps, but can be used for domestic
purposes if kept clean from sewage pollution.
The study team conducted tests on the physical
properties of the water with the assistance of the
Coxâ&#x20AC;&#x2122;s Bazar office of the DoE. Samples were taken
from up-stream and down-stream of Gondhom
Chara, Balukhali Chara, Talipara Chara, Hakimpur
Khal, Palong Khali Khal, Tangkhali Khal and from
a number of ponds. Tests were conducted for
pH, dissolved oxygen (DO), total dissolved solids
(TDS), electro conductivity (EC) and temperature.
Test findings reveal that some of the streams are
becoming devoid of oxygen down stream from the
camps. In some samples, EC was also observed to
be high. Uncontrolled open defecation practices
along the banks of the ponds and streams and the
sedimentation deposits in the streams are most
likely the reasons for the deteriorating water quality
of the available surface water (Appendix E).
In the makeshift Leda camp where Rohingya
were living before 25th August 2017, an alternate
source of water has been established from the

surface water pond. There, pond water is treated
and supplied to the inhabitants of the camp. The
population is small so this solution is manageable.
Ground water depletion/contamination has been
identified as a critical impact of the Rohingya
influx. Surface water is limited, the shallow water
aquifier is drying up (and may not be adequately
replenished by rainfall) and the availability of water
from the deeper aquifier remains uncertain.

5.1.3 Acoustic Environment
Increased traffic on the Coxâ&#x20AC;&#x2122;s Bazar-Teknaf road is
the main source of noise as the camps are along
this road. The impact of noise generation on the
settlements is not significant as most of the camps
are at some distance from the road. Some internal
roads have been constructed to facilitate the
connectivity between the camps, but traffic on
these roads is still very light.
Noise is generated at the set times when relief
materials are distributed, but measures introduced
by the Bangladesh Army in charge of the
distribution of relief materials have kept noise levels
within reasonable limits.

5.1.4 Air Quality (Indoor)
The air quality in the influx area has slightly
deteriorated along the roadside areas of the camps
because of increased traffic. Brick kilns in Ukhia and
Teknaf may also be contributing to the problem.
The study team did not notice a significant impact
in the camps but inhabitants have reported that
they suffer from the dust generated from the loose
soil when strong winds blow; serious dust pollution
during stormy winds is an issue. From a health point
of view, this should not be a great concern as the
size of the dust particles does not allow them to
penetrate into the respiratory tract.
Indoor air pollution in the camps from cooking
is a serious concern especially for women and
children, and has been identified as having a severe
impact. All cooking is carried out inside the poorly
ventilated shelters (the only opening in an 8/8 sq. ft.
space is a door at the front) and the firewood which
is used as fuel produces large quantities of smoke
that stays in the air long after the fire has been

5.1.5 Solid Waste Management
Solid waste management refers to the collection,
disposal and recycling of solid waste materials.
Waste materials need to be separated before they
leave the shelter but currently there are neither
primary collection centres nor an organised
collection centre in the camps. Solid waste
management will be an issue for as long as the
Rohingya remain in the camps. The study team
identified the impact as moderate to severe.
Principal waste materials are the polythene bags
in which relief provisions are distributed. Other
waste materials include kitchen garbage, food
packaging materials, batteries and plastic bottles.
Of these, recycling efforts are only beginning to get
underway for plastic bottles. Due to the scarcity of
firewood, some families use plastic as a cooking
fuel, a practice which is extremely harmful.
Awareness raising initiatives should be undertaken,
an organised disposal and collection system is
needed and responsible disposal, for example of
batteries, needs to be encouraged.

5.1.6 Soils and Terrain
Landslide is one of the most serious and potentially
destructive disasters in the Chittagong hilly
region as the hills are formed of unconsolidated
sedimentary rocks. Due to hill cutting in an
indiscriminate manner to provide shelters for the
Rohingya influx, the terrain of the hills has lost its
natural setting and the vegetation cover has been
removed. Weak soil structure has accelerated the
process of soil erosion and the top soil and other
loose soils have now become highly susceptible to
being blown away in rain or in stormy winds.
When the study team visited the camps, its
members noted that about 50% of the hills in
the influx area had been completely denuded.
Erosions in some areas are already causing drainage
congestion or blockages. The hills in some places
have been so severely cut that a landslide may
happen at any time.

Cut of Hill Slopes

|

Photo: UNDP Bangladesh/Arif Faisal

Land stability is also a threat and both slopes and
flat terrain are increasingly unstable. In the case of
heavy rains, minerals from the soil will dissolve very
quickly and the soil will turn into heavy mud. The
steep slopes of the hill will not be able to carry the
mass weight of the wet soil or mud and that would
result in a land slide. Measures need to be taken to
stabilise the slopes and terrains of the hills before
the onset of the next monsoon rains. The study
team has identified the issue of land stability as a
severe impact.

5.1.7 Summary of Physical Impacts
All high significance risks have to be mitigated to
an acceptable level. In particular the impacts on
groundwater may give rise to significant social
conflicts between the host communities and
Rohingya over the use of water resources.
Some of the impacts, such as ground water quality
and quantity, loss of soils and terrain instability
appear to be irreversible in the short-term;
several years may be required to restore original
conditions. Most of the physical impacts are likely
localised within or near the footprint of the camps
and do not have the potential to act in a cumulative
fashion with similar impacts from other activities
in the area. The quality of surface water may be an
issue outside the footprint of the camps but it is
unlikely that the main water artery of the region
(the Naf River) will be substantially impacted by the
contaminated waters of intermittent creeks and
small rivers passing through the area of the camps.

47

5 . 2 I M PA C T S O N
ECOSYSTEMS

Table 5-1 summarises the levels of physical
environmental impacts. These levels are equally
applicable to both the current situation and
to the forseeable future if the impacts remain
unmitigated.

5.2.1 Forestry
The whole forest land in the influx area of influence
is assessed as 26,600 ha (or 44% of the total 60,000
ha landscape, see Table 4-1). Setting up large
makeshift camps in the Kutupalong – Balukhali and
other areas has made a substantial direct impact
on the available forest resources in the Ukhia range
(affected 3,525.2 acres or 1,427 ha, see map on
Figure 4-4 and satellite photos in Figure 4-6). This
causes additional stress on the Ukhia forest land
that has reportedly already been cut by 30-40% by
the ongoing deforestation process. In the Teknaf
Range the influx has also impacted some of the
plantations in the buffer zone and has reportedly
started impacting the core zone of the TWS as well.
However, it appears that the ‘natural’ forest is mostly
shrubland which did not sustain a dynamic forest
ecosystem before the influx.

Direct Impact on Plantations
A total of 3,713 acres (1,502 ha)53 of forest lands
under the Ukhia, Whykong and Teknaf forest range

have been taken over by the Rohingya makeshift
settlements. Among all the encroachments, 1,960
acres (793 ha) of natural forest land and 1,753 acres
(709 ha) of plantation area have been recorded
(Table 5-2).
According to the FD, the plantations that have been
encroached upon were mostly established under
the Social Forestry Programme. The plantations are
composed of both short rotation (10 years) and
long rotation (25 years) species.
With the destruction of social forest plantations,
more than 1,500 participants have lost their
benefits as almost all the plantations in different
years have been cleared for the makeshift
settlements. Minimal remnants of plantation have
been seen between the camps of Hakimpara and
near the Leda camp. According to Key Informant’s
interviews (KIIs) and Focus Group Discussion
(FGDs), it is expected that what remains of the
plantations may be razed at any time for the needs
of newly arriving Rohingya.

Table 5-2: Impact of Rohingya influx on forest land of the Cox’s Bazar South Forest Division (up to 04
Nov 2017).
Upazila

Location of the Rohingya camp

Encroached forest area

Forest
Range

Legal
status

Forest
Beat

Rohingya camp
Balukhalidhala
Tasnimakhola

Ukhia
Ukhia

53

Thainkhali Mokkrar billHakimpara, JamtoliBagghona,

Reserve
Reserve
and
protected

Sofiullah Kata
Ukhiar
ghat

Balukhali

Ukhia
Sadar

Kutupalong

Reserve

Social
forestry
plantation
(acre)

Natural
forest
(acre)

Total
forests
(acre)

152.70

135.3

288

177.5

214.5

392

271

236

507

92.5

108.7

201.2

450

359

809

535

793

1,328

Cox’s Bazar South Forest Division, November 2017.

49

Upazila

Location of the Rohingya camp

Encroached forest area
0

65.2

65.2

74.20

1.0

75.2

0

31

31

0

16

16

Total, acres

1,752.9

1,959.7

3,712.6

Total, ha

709

793

1,502

Whykong
Teknaf
Teknaf

Roikong

Putibunia

Whykong

Karantoliy-Chakmarkul

Mochuni

Noyapara
Leda

Fuelwood and Bamboo Use
It is reported by various stakeholders, including
surveyed Rohingya families, and observed during
the field reconnaissance, that Rohingya have
been collecting fuelwood from the natural and
community forests for a long time. The available
information is not sufficient to estimate the
sustained damage to the forest, but it is clear that

Protected
Reserve
Protected

continued demand for the fuelwood will inevitably
push Rohingya to further encroach in the natural
forest and plantations (if allowed) and expand
deforestation on a substantial scale.
A rapid social survey in the Leda and Sofiullar Kata
Rohingya camp shows that the average fuelwood
consumption by a Rohingya family is 151.07±47.25 kg/
month where the average number of family members

Table 5-3: Biomass and carbon loss from the plantation due to the makeshift settlements in the
Ukhia and Teknaf forest range in Cox’s Bazar South Forest Division
Forest
Range

Forest Beat

Ukhia
(n=34)

Thaingkhali

Teknaf
(n=34)

Muchuni

Fresh biomass54

Total ovendry biomass
(tons/ha)55

BBD (tons/ha)

Total biomass
(tons/ha)

587.72±157.44

96.35±26.53

684.07±180.51

256.53±67.69

333.48±127.33

63.70±22.79

397.18±150.07

148.95±56.28

ACD (tons/ha)

BCD (tons/ha)

Total carbon56
(tons/ha)

Carbon

Ukhia
(n=34)

Thaingkhali

110.2±29.52

18.07±4.97

128.26±33.84

Teknaf
(n=34)

Muchuni

62.53±23.88

11.94±4.27

74.47±28.14

Notes: ABD-Aboveground biomass density; BBD-Belowground biomass density; ACD-Aboveground carbon density; BCD-Belowground carbon
density.
The aboveground biomass (ABD) of trees was estimated using the allometric model described by Pearson et al.(2013): Biomass (kg/tree) = exp(2.289+2.649*lndbh-0.021*lndbh2), where lndbh is the natural logarithm of tree diameter. The belowground biomass density (BBD) was found using the
Biomass (kg/tree) = exp(-1.0587+0.8836*ln(aboveground biomass)), where ln is the natural logarithm.

Table 5-4: Fuelwood and bamboo used in the Rohingya camps in Ukhia and Teknaf areas of Cox’s Bazar.
Rohingya camp

Average
family size

Average number
of bamboo

Fresh weight of
the bamboo (kg)

Average fuelwood
(kg/month)

Leda (n=30)

6.54±1.94

60.69±7.75

310.78±73.31

156.92±37.06

Sofiullar Kata (n=30)

7.53±2.95

66±14.56

400.67±74.01

146±55.92

Mean

7.07±2.54

63.54±11.99

358.93±85.52

151.07±47.25

is 7.07±2.54 (Table 5-4). Fuelwood was mostly bought
from the local market, but it was confirmed that all the
fuelwood had been collected from the nearby forests.
For the construction of settlements, bamboo was used
as of 63.54±11.99 culms/family with the fresh weight
358.93±85.52 kg/family.

Fuelwood Collection
Forest degradation due to fuelwood collection has
been an ongoing issue in the area for a long time.
As shown in the FAO report, even before the 2017
Rohingya influx, the available biomass supply was
less than the demand of the host community and
of the Rohingya previously settled in the area. To
assess the additional potential damage to the forest
land from fuelwood collection caused by the most
recent Rohingya influx this study developed two
scenarios which assume collection of fuelwood
within areas of 5 km and 10 km around the camps
(see Figure 5-1 and Appendix F). The total monthly
requirement of fuelwood, collected by Rohingya
people in the forest, is currently estimated to be
6,800 tons.57
The area of land cover falling within the footprint
of the camps and within the 5km and 10km buffers

around all camps is presented in Table 5-5.58
Baseline data refers to land cover falling in the
whole AoI for 2015 (see Figure 4-4). Table 5-6 shows
that approximately 50% of forest land lies in the
5km buffer and 95% of forest land is in the 10km
buffer. In other words, practically all forest land
remaining in the AoI will be cleared if the impact
covers all of the 10km buffer. The study assumes
impacts of complete clearing of forest lands in the
camps’ footprint (including plantations). Within
the 5 km and 10 km buffer, we assume impacts
on natural forest (shrub dominated areas, shrub
dominated forest and hill forest). The impact on
existing plantations within the 5 km and the 10km
buffer is presented in a separate line of the table.
Table 5-7 presents the estimated biomass available
in the forest land.
As shown in the IOM and FAO (2017) report,59 the
average demand of fuelwood per day per person
was 0.7kg prior to the August 2017 influx. This
number correlates with the results of the field
survey (see Table 5-4). As stated in the report,
Rohingya collected approximately 50% of their fuel
demand from the forests.

As presented in Table 5-7, the collection of
fuelwood from the natural forest within the 5km
buffer around the camps will sustain fuel supply
for approximately four months, but the forested
area of 14,000 ha will be degraded and converted
into shrub dominated areas with low biomass
and productivity. If fuelwood is collected from
plantations, the supply may last for an additional
11 months. Collection of fuelwood from the natural
forest within the 10km buffer around the camps will
sustain fuel supply for approximately one year, but
the entire remaining forest land of 26,000 ha will
be degraded and converted into shrub dominated
areas with low biomass and productivity. There will
also likely be significant losses in biodiversity (see
Section 3 Baseline). If fuelwood is collected from

plantations, the supply may last for an additional 31
months.
These scenarios represent an indicative assessment
of the potential impact of fuelwood collection
on forest land and social forest plantations.
Key assumptions are based on the results and
conclusions of the IOM & FAO (2017) report. The
actual rate of deforestation may differ from the
modeling results and has to be monitored and
mitigated.
The Nishorgo network60 found 29 stakeholders who
were directly involved with forest degradation and
deforestation in the TWS who were also involved in
other protected areas of Bangladesh. The primary
stakeholders involved fuelwood/timber collectors,

betel leaf growers, forest produce collectors,
hunters, and fishermen. The other key agents who
had an indirect influence on forest degradation
and deforestation were brick field owners, timber/
fuelwood merchants, and sawmill and tea stall
owners61.

Parameter

Buffer of
5 km

Time required to
18
consume all available fuel months
wood from plantations
***

Buffer of
10 km*
31
months

* Buffer of 10 km includes buffer of 5 km. Both buffers exclude
campsâ&#x20AC;&#x2122; footprint
** Assuming 0.7 kg of dry fuel wood required per person a day,
650,000 people. Assume 50% of required fuel wood collected in the
forest. 0.7*650,000*0.5/1000 = 6,825.
** Assuming no fuel wood is coming from outside of the AoI.
Assuming zero natural rate of accumulation (forest growth) in the
AoI since the pre-2017 influx consumption of fuelwood has already
increased the available supply62.

Figure 5-1 Potentially Impacted Areas

Rohingya family extracts last remaining tree stump and roots from
the hill slope for fuelwood | Photo: UNDP Bangladesh/Arif Faisal

Table 5-7 Available biomass and fuelwood
demand in the AoI
Parameter

Buffer of
5 km

Buffer of
10 km*

Total biomass available
from natural forest, tons

28,100

74,300

Total biomass available
from plantations, tons

124,100

211,600

Biomass required for
650,000 people, tons/
month**

6,825

6,825

Time required to
4 months
consume all available fuel
wood from natural forest
***

61

11
months

Tani M, Rahman MA. 2018. Deforestation in the Teknaf Peninsula of Bangladesh: A Study of Political Ecology. Springer, Singapore.

5.2.2 Protected Areas and Critical
Habitat
The existing Rohingya camps located in the
Teknaf area continue to impact the TWS. The
Rohingya camps in the Kutupalong-Balukhali and
Leda-Nayapara areas do not directly impact the
protected areas (Figure 5-2), but the fuelwood
collection, if continued unabated, will inevitably
have a substantial impact on TWS, on the proposed
Inani National Park and potentially on Himchari
National Park. The Himchari National Park, though
located further north of the influx AoI, may be
impacted by fuelwood collectors if they run out of
resources near the camps. Table 5-8 presents the
estimated size of the Protected Areas potentially
impacted by the fuelwood collection.

5.2.3 Vegetation
To date, up to 7% of the total area occupied
by plantations and orchards and 3% of shrub
dominated forest in the AoI have been cleared
to set up makeshift camps for the Rohingya.
Potentially, and in the long-term, more than 61% of
the plantations and remnants of natural forest may
be degraded and converted to shrub land due to
the influx. (see Table 5-6).
The IUCN63 has already listed the forest species
of Bangladesh which are threatened. This covers
most of the species still found in the TWS, in the
Himchari National Park and in the proposed Inani

National Park in Cox’s Bazar. Clearing of vegetation
and degradation of the forest land has a significant
impact on landscape diversity, vegetation
abundance and species diversity.

5.2.4 Wildlife
The makeshift camps have a significant impact
on wildlife and food shortages, shrinking habitats
and disruptions in breeding grounds are affecting
nocturnal, metaturnal, crepuscular and diurnal
wildlife. More that 67% of the mammal wildlife are
terrestrial, and of this number, around 63.8% rely on
forests as a habitat. Arboreal species are also under
severe threat due to the ever-decreasing natural
forest area.
The globally endangered Asian Elephant (Elephas
maximus) is ‘critically endangered’ in Bangladesh.64
Host and Rohingya communities are encroaching
on its habitat in the Cox’s Bazar Forest Division, and
both resident and migratory elephants are facing
a continuous shrinkage of their habitat and food
supply. To date, 268 resident wild elephants, 93
migratory elephants and 96 captive elephants have
been recorded in Bangladesh65.

5.2.5 Marine and Freshwater Ecosystems
The Rohingya settlements are not anticipated to
affect the marine and fresh water environment
directly, but there will be indirect impacts on the
stream flows in future.

Table 5-7 Available biomass and fuelwood demand in the AoI
Protected Area

5.3 GENDER ISSUES AND
H U M A N H E A LT H
The crisis disproportionately affects women,
girls and the most vulnerable and marginalised
Rohingya population groups (based on gender,
age, marital status, sex of household head, mental
and physical disabilities, sexual orientation and
gender identity) by reinforcing, perpetuating
and exacerbating pre-existing, persistent gender
inequalities and gender-based violence and
discrimination.
The overcrowding and limited privacy at all
Rohingya sites raise safety and security concerns,
particularly for women and girls. In addition,
increasing gender isolation and the restricted
mobility of women and girls limit their access to
life-saving assistance, services and information66.
According to a 2015 gender analysis study67,
which included a focus group discussion and key
informant interviews among the 3,000 Rohingya
who were then living in the official Rohingya camps
in Coxâ&#x20AC;&#x2122;s Bazar, 53% believed that women should
not be allowed to leave the house, while 42% of
surveyed women reported spending an average
of 21 to 24 hours a day inside their house. Such
socio-cultural aspects need serious consideration
with regards to any response/recovery effort. Lack
of sufficient lighting in camps further exacerbates
such risks and negatively affects the sense of safety
that women and girls have.
Various assessments report that the current
local market supply of fuelwood has not met the
increased demand since the Rohingya influx. The
self-collection of firewood from nearby forests
is reportedly linked with severe safety risks,
particularly for women and girls, including genderbased violence, trafficking, elephant attacks and
the potential for natural resource related conflict
with host communities whose livelihoods are being
depleted. Women and girls, especially from femaleheaded households or child-headed households,

are particularly vulnerable to violence and abuse
while collecting firewood from the forest. Lack of
sufficient cooking fuel results in households either
undercooking food, or skipping meals (often to as
few as 10-15 meals a month), with women and girls
being the first to eat less or last within households.
Distribution of health facilities remains inequitable
due to limited land availability, poor road access
and high densities of Rohingya in inadequate
space. The risk of communicable disease remains
high due to crowded living conditions and poor
water and sanitation facilities. Uncontrolled
construction of latrines by different humanitarian
service providers and/or private sector and/or by
individuals without conforming to the standard
practices and lack of awareness on the risks they are
likely to pose, have created a sanitation hazard in
the camps.
When latrines are quickly filled, a new set is often
installed nearby, addressing sanitation needs in a
most unsanitary way. In some cases, de-sludging
of latrines has taken place using inappropriate
disposal sites. Water points have also been set up
at close proximity to latrines. There is the likelihood
of leakage and seepage to the shallow aquifer
from these latrines. Ideally a minimum horizontal
distance of 30 m should be maintained in between
water points and latrines.
The study team identified the sanitation hazard
as a severe impact of the crisis. As the emergency
phase settles, service providers need to rethink the
whole issue of good practices regarding sanitation
and drinking water from the point of view of both
the environment and health. One possible solution
is the promotion of pit latrines followed by the
desludging of existing latrines in an appropriate
manner. Proper maintenance of the water points is
also needed.
The overcrowding within the camps exacerbates
many risks and limits the ability of humanitarian
actors to provide comprehensive protection

services. Basic infrastructure including
water points, lighting and WASH facilities
are at considerable distance for many,
that can lead to safety issues, particularly
for women and girls.
A lack of natural resources limits
nutritional intake and can have further
adverse impacts on the health of an
already weakened group. Shortage of
fuelwood may result in the undercooking
of food. A very high percentage of
adverse health impacts is related to fecal
and chemical contamination of drinking
water and the ease with which disease
can be transmitted in the overcrowded
Rohingya camps. Dust and smoke, created
by the burning of low-quality fuelwood,
heightens the incidence of respiratory
disease. Most of these problems tend to
affect disproportionately the vulnerable
groups, i.e. women, the very old or the
very young.
Recent FAO, IOM, WFP and UNHCR
assessments68 indicate that securing
alternative fuel and improved cooking
stoves is a key practical and strategic
gender issue for the well-being and
empowerment of Rohingya women and
girls. As a result of strict gender-defined
roles, the burden of household work
and highly conservative social norms,
Rohingya women spend a significant
amount of time inside the shelters. They
report inhaling toxic emissions and
suffering from the high heat from cooking
inside poorly ventilated shacks as serious
concerns which lead to health issues
such as respiratory problems and eye
infections.

Critical /
High
(no comparative
evaluation has
been made
in the site
selection)

Severe/High

4. Site
congestion
and
landslides

5. Lack of
toilets and
bathing
facilities

3. Indoor air Severe/
High
pollution
due to
conventional
cooking
stoves,
kitchen
design and
fuelwood

Impact/Risk

250,000

4.4. Arrangements for fire prevention and safety
Human settlements should respect a 50m buffer
zone around streams and wetland ecosystems.

300,000

50,000

4,3. Urgent actions to stabilise the steep slopes of
the hills to minimise risks of landslides (engineering
and biological reinstatement of soils and terrain).
Replant deep root light trees, grass and bushes to
stabilise slopes. Construct retaining wall in foothill.

5.1 Set up make-shift bathrooms with tube-wells at
convenient distances for the women to be able to
regularly use the facility.
5.2. Set up separate toilet blocks for women at
convenient distances
5.3 Ensure adequate lighting at the toilets for
protection measures

400,000

4.2. Urgent need to decongest the main site as life is
not sustainable at the current concentrations

Improvement
of toilets
and bathing
facilities for
women in
the makeshift
camps

1.2 M

4.1. Preparation of a contingency plan for
emergencies such as fire, landslide, heavy rainfall,
cyclone and/or non-availability of water

3.1. Shelter cluster should focus on proper
ventilation while developing improved housing
design for the Rohingya. Also need to communicate
the importance of and proper use of safe cooking
stoves, e.g. ICS, LPG stoves. Community kitchens
could be another option. These will benefit the
health of women and children as indoor pollution
will be substantially reduced and direct exposure
of women and children to emissions will be
significantly minimised. Finally, the likelihood of fire
is high in dry season, so safety measures for cooking
indoors should be well propagated.

Host
Communities
and Rohingya
population
1.2 M as of 26
Nov 2017
Potentially
more than
50% (10,00025,000 ha)
of remaining
forest degraded
in the area.

People
concerned

SCG CXP,
GoB, UNDP,
International and
National NGOs

350,000

Briq 85,000
LPG
315â&#x20AC;&#x2122;000
650,000

50,000

Recommended Actions
8.1. Wood supply and extraction; organizing
controlled access to fuelwood from the natural
forests and village forests.
8.2. Support fuelwood substitution actions through
coordination of various aid organizations (an
ongoing process) and promote community cooking
with briquettes and Liquefied Petroleum Gas (LPG)
8.4. Set up tree plantations in wood lots on shrub
and barren land (e.g. abandoned sites), along roads,
pathways, river banks, embarkments and fences)
8.5. Introduce social forestry plantation, community
forestry and agroforestry

Afforestation
and
reforestation
through Social
Forestry and
Agroforestry.
Increase wood
productivity.

8.6. Designated areas for bamboo afforestation
should be declared, and bamboo regeneration and
propagation projects should be addressed.
8.7. Afforestation along the coastal line with
casuarina equisetifolia (Jau tree) and other fast
growing native species and suitable mangrove;
introduce social forestry wood lots or community
forestry, agroforestry for host communities
8.8. Reforestation at Coxâ&#x20AC;&#x2122;s Bazar South and North
Forest Division for compensation of lost forest
areas in the area where the Rohingya live. Initiate
community forestry/social forestry and agroforestry
practices.
8.9. Elaboration of a comprehensive development
forestation plan/plantation programme for the next
five years.
8.10. Develop and implement closure and
reclamation plans for abandoned camps, including
landscaping, drainage, soil restoration, stabilisation
and reforestation.
8.11. Work with potential development partners to
gain synergy on pipeline forestation projects - World
Bank plans to start such a project (SUFAL) and FD is
designing a project (SUROKSHA) in the Chittagong
Hill Tracts and Coxâ&#x20AC;&#x2122;s Bazar by mid 2018.

Beneficiaries Partners

Recommended Actions

63

Impact/Risk
Level

9. Vegetation Critical/
High
and wildlife
diversity and
abundancy
losses in
Protected
Areas, and
other forest
land

Impact/Risk

Host
Communities
450,000

People
concerned
Conservation
of protected
area and its
enhancement.
Declaring
protected areas
and enhancing
the surveillance
of the existing
PA

Mitigation
Measures

9.8. Support the ‘Conservation, Management and
Development of Sonadia Island’ project.

9.7. Support the existing project ‘Strengthening
and Consolidation of Community Based Adaptation
(CBA) in Ecologically Critical Areas through
Biodiversity Conservation and Social Protection’.

9.6. Establish Inani National Park as quickly as
possible and ensure availability of funds and
resources for its operation.

9.5. Develop a biodiversity conservation plan,
including enhancement of natural and critical
habitat in Cox’s Bazar district

9.4. Establish an Environmental Coordination Unit
together with humanitarian aid community for the
area where Rohingya live; ask NGOs dealing with
environmental management to recruit professional
staff who will work with FD and DoE to conserve
and manage natural resources and activate comanagement committee/community conservation
group

9.3. Support of Community Patrol Groups.

9.2. Protected areas such as TWS should step up the
surveillance of their geographical boundaries.

Host
Communities
450,000

9.1. Effectively protect the Teknaf Wildlife Sanctuary
(TWS), Himchari National Park, and proposed Inani
National Park with needed resources to enforce the
national legal requirement for resource use in the
protected areas (e.g. strict ban on wood cutting,
felling, vegetation destruction /clearance and
fuelwood collection from and village forests).

10.2. Ensure protection of Rohingya from elephant
25 km of
intrusions with combined fences (trees, bamboo and fence
solar powered electrical fences near the camp areas
in Ukhia and Teknaf

10.1. Plant fodder plants in the forest to ensure food
for elephants.

Recommended Actions

65

Introduce improved cooking
stove and alternative fuel

Set up separate bathing
spaces and separate toilets.

Severe/ High

15. Due to excessive felling of trees
and excessive demand, fuelwood
has become scarce and costly for
local women

16. Rohingya women are hesitant
Severe/ High
to use common toilets and to bathe
outside/on tube-well platforms,
and so use a corner in the shelter as
their toilet and bathing space, thus
making the shelter unhygienic

14. Women and children having
Severe/ High
respiratory problems due to
inhaling smoke from cooking inside
ventilation-less shelters

Impact/Risk

Comment

16.1. Set up make-shift bathrooms with
tube-wells at convenient distances for
women to be able to regularly use the
facility.
16.2. Set up separate toilet blocks for
women only at convenient distances
16.3. Ensure adequate lighting at the toilets
for protection measures

15.1. Distribute improved cooking stoves to
local households.
15.2. Distribute alternative fuel (BRH, LPG,
etc.) to local women.
15.3. Support host communities to set up
shops on alternative fuel in the vicinity of
the shelters to cater to the needs of the
Rohingya.

Addressed in line #5 above

Addressed in line #8 above

Addressed in line #3 above
14.1. Distribute improved cooking stoves
to the Rohingya women as per the
recommendations in the joint assessment
carried out by the Shelter and Non Food
Item (NFI) sector of ISCG.
14.2. Provide orientation training to the
Rohingya women on the safe and efficient
use of the cooking stoves or use of improved
cooking stoves (ICS).
14.3. Distribute alternative fuel (BRH, LPG,
etc.) to the Rohingya women.
14.4. Set up and promote community
kitchens for women and children to avoid
cooking inside shelters where possible
(given the cultural barrier of women going
outside)

Provide orientation training to Rohingya women on
the safe and efficient use of the cooking stoves.

Develop training programmes to educate local and
Rohingya communities about the impact of forest
extraction and improved cooking methods.

2.5. Undertaking environmental training and
awareness programmes.

Recommended Actions

850,000

850,000

1.2 M

Beneficiaries

67

PROPOSED MONITORING PLAN
The proposed monitoring program will:
Confirm, where appropriate, that mitigation measures are functioning as
predicted;
Detect changes and trends in the environment;
Establish a periodic ecological monitoring system in the forest ecosystem and
wildlife habitat areas;
Identify cause-effect relationships for detected changes and trends in the
environment;
Allow for adaptive management to address impacts that have not been
properly mitigated or offset.

International Red
Cross to continue its
regular monitoring
of ground water.
DPHE could also
initiate regular
testing of ground
water

pH, EC, Arsenic, Iron.
Phosphate, Chloride,
Salinity

20 samples from wells of different 4 times a
levels covering old camps and
year
new camps in Kutupalong area.
10 samples from wells of different
levels covering old camps and
new camps in Balukhali area.
2 samples from wells of different
levels from each of the other
makeshift camp areas.

CONCLUSIONS
The 2017 Rohingya influx has had major impacts on the environment of Coxâ&#x20AC;&#x2122;s
Bazar District that require the implementation of a mitigation programme and
offsets to prevent the environment from significant degradation. Significant
adverse impacts on various environmental components have been caused both
by the direct footprint of the Rohingya camps and by increased anthropogenic
pressure far beyond the boundaries of the area of the camps.
If the environmental impacts of the influx continue unmitigated, the already
heavily degraded protected ecosystems will soon suffer significant conversion
and degradation, substantially reducing the habitatâ&#x20AC;&#x2122;s ability to maintain viable
populations of its native species and losing its ability to sustain its ecosystem.
The disturbed landscape will have reduced water retention capacity which may
impact ground and surface water in the area.
The GoB strategy is to group the Rohingya in a set of large camps (in the
Kutupalong and Balukhali area) and relocate part of the Rohingya to Bhashan
Char72, rather than deal with a multitude of small camps located across the
Teknaf and Ukhia upazilas. This strategy appears feasible from the management
point of view, but it will be a major challenge to sustain the operation of large
camps located in the vicinity of environmentally sensitive areas which have
limited water and forest resources. The best option to avoid the environmental
impacts of the influx would be a relocation of the makeshift camp to a less
environmentally sensitive area and a disintegration of the mega camps into
smaller units settled at some distance from protected areas and critical habitats.
This however is not likely to be a feasible solution in current conditions.
The proposed mitigation addresses two key bottlenecks that threaten the very
existence of the makeshift camps: access to potable water and fuel for cooking.
Both issues can be resolved if proper alternatives prove to be feasible in the short
term (one to three months).
Sanitation, indoor air quality, terrain stability, solid waste and fecal waste
management are all major risks to human health in the camps. These issues can
be addressed by better planning, resettling and improvement of minimal living
standards.

Protection of natural and critical habitats is
important even though the immediate impact on
the ecosystems is of a cumulative nature and is
less visible immediately. The proposed mitigation
requires addressing land and resource use patterns
by both the host communities and the Rohingya.
Forest degradation has been a longstanding
issue in the area and it has been exacerbated
by the Rohingya influx. Enforcement of strict
rules of resource use in the protected areas and
establishing the proposed Inani National Park
will mitigate unregulated and illegal access to
fuelwood. The confirmation and enforcement of the
ban on fuelwood, wood and bamboo collection
from the protected forest should complement the
alternative fuel programme in the area both for
host communities and the Rohingya people.
Protection of the Rohingya from elephant
intrusions needs to be ensured. Combined fences
(trees, bamboo and electrical fences and light
watch towers) should be installed near the camp
areas in Ukhia and Teknaf.
Proposed actions to address the issue of the
degraded forest habitat and compensate for the
lost forest areas under the campsâ&#x20AC;&#x2122; footprint are:
Protection of natural forests;
assistance to community forestry;
reforestation of shrub-dominated areas and
abandoned camps;
afforestation along the coastal line; and
agroforestry.

Plans are also needed: to restore the livelihood of
the beneficiaries of social forestry programmes; to
develop and implement closure and reclamation
plans for abandoned camps; to establish
designated areas for bamboo regeneration; and to
consider the enhancement of natural habitats in
other areas of Bangladesh to ensure no net loss in
biodiversity.
Current experience with managing influxes shows
that when asylum seekers become repatriated or
integrated, there are limited funds remaining for
the closure and reclamation of the abandoned
camps and associated facilities, reforestation of
the degraded lands and conservation of wildlife
habitat. The GoB should secure adequate resources
to ensure that the restoration of the eco-system
in the wake of the Rohingya influx is adequately
supported.
Extensive environmental management and
detailed long-term monitoring programmes are
recommended to confirm and quantitatively define
the results of this indicative Rapid Assessment
Study, and mitigate the environmental damage and
loss and damage from the influx. The programmes
should be integrated into the UN Humanitarian
Response Plan process and led by the MoEF,
MoDMR and other relevant ministries and line
agencies.

Community safety risks due to both accidental
and natural causes, especially where the structural
elements or components of the project are
accessible to members of the affected community
or where their failure could result in injury to the
community throughout project construction,
operation and decommissioning

X

Hill cutting may cause terrain instability
and landslides during the monsoon season.
Improperly constructed shelters will not
protect Rohingya from cyclones.

Generation of solid waste and/or hazardous waste

X

Dumping of solid waste. Filtration of human
waste from latrines

Use of chemicals

X

Generation of wastewater during construction or
operation

X

Responses to the screening questions indicate
that the Rohingya influx to the Coxâ&#x20AC;&#x2122;s Bazar District
of Bangladesh has caused or will cause most

Selling of fuelwood by Rohingya in village market near camp

76

No

|

Poor drainage and waste water collection /
treatment

of the indicated environmental impacts. These
environmental impacts are diverse, unprecedented
and, in some cases, irreversible.

Hilly area with small
creeks mostly dry in
winter season. Some rice
fields and small water
ponds observed

Where is this event taking place?
Country

Bangladesh

District

Cox’s Bazar

Sub-districts

Ukhia, Teknaf

Ratio of Rohingya people to local population
(within a defined geographical limit for villages
Estimated number of
Rohingya people

838,000 (26.11.2017)

Is the REA being carried out before or after the
population influx?

Estimated number of
local population

300’000 in Ukhia,
200’000 in Teknaf

Before

Ratio of Rohingya to
local population

Approx. 2:1

After

X

During

X

Unknown

Has this area previously hosted refugees? If “Yes”
what were the impacts and what actions were
taken to address these?
Yes. The Rohingya camps were established in the
area in the 1970s with a total registered Rohingya
population of approximately 40,000, of whom
33,000 have been residents of registered camps in
Teknaf and Ukhia since 1992. Approximately 70,000
Rohingya arrived between October 2016 and
February 2017. The total number of registered and
unregistered Undocumented Myanmar Nationals
(UMN) in Bangladesh is estimated to be as much
as 650,000 (ISCG site report of 26 November) and
the main makeshift settlements are located at
Kutupalong (North) and Leda (South)
Define the physical boundary of this REA, e.g.
does it include local villages or distant areas that
might be used to source natural resources?

What is the predominant environmental
situation?
Small relicts of Rainforest West of Coast Range in
of Dipterocarpaceae
Teknaf and Ukhia
Dry forest

No

Savannah

No

Barren land

In Ukhia on abandoned
camp sites

Agricultural land

In Ukhia and Teknaf:
Rice, betel palm and
betel leaf in green
houses; home gardens
with various fruit trees
and vegetables

Other (please describe)

Cattle, goats, sheep

When is the REA being carried out?
Month

November 2017

Wet or dry season (e.g.
monsoon)

End of a late rainy season

77

Have any environmental threats/concerns been identified?
Yes.
Contamination of ground water by human waste from latrines
Surface water pollution
Lack of drainage
Soil and vegetation removal
Fuelwood collection from the forests, trees, roots extraction in the abandoned camps (left side of the Road
#1 in Balukhali)
Indoor air pollution due to wood fire cooking in the shelters
Loss of terrain stability due to hill slope cutting to set up shelters
Soil erosion - potential for landslide in rainy season (heavy monsoon rains)
Omnipresent dispersed solid waste, fly dumping in ravines
Fire hazard due to close proximity of the shelters
Unhealthy odour due to setting up of makeshift latrines and bathing spaces inside shelter
Noise and dust from road traffic
What type(s) of fuel(s) are used or are likely to be used for the following applications?
Application

Local inhabitants

Rohingya people

Comments (e.g. source of fuel)

Cooking

LPG / fuel wood

fuel wood / rice
husk briquettes /
LPG /biogas

Fuelwood mainly from forestland in
the vicinity of the camps, briquettes
provided by aid agencies/ biogas
kitchens installed by aid agencies in old
camps/ LPG from local market

Heating

No

No

Income
generation

Cropping for host and Rohingya
community, production of
goods and services in demand
by aid organisations, restaurant,
market activities

Rohingya people
sell NFI and
collected fuel
wood

Rohingya people are not yet allowed to
be employed for financial gain

Industry

Production of baked bricks

No

With coal and fuelwood

Road
construction

Waste rags from the textile
industry

To produce tarmac cover

What type(s) of construction materials are used or are likely to be used for the following applications?

National NGOs and
international NGOs build fences
around their compounds bamboo, wire, plastic sheeting,
or a combination of all of these

How will social customs or practices of the Rohingya people and the local population impact the
environment?
Water withdrawal from shallow water wells will deplete the aquifer.
Close proximity of the latrines to the water wells will cause biological contamination of ground water.
Collection of fuelwood and construction will likely affect forest ecosystems.
Cooking using fuelwood and briquettes impacts health via indoor air pollution, especially that of the
Rohingya women and children.
Conservatism of the Rohingya population prevents women from bathing in the open, and may restrict their
use of common latrines, resulting in women dealing with their toilet and bathing needs inside shelters in
unhygienic conditions and creating health hazards for themselves and other family members.
Encroaching on wildlife habitats may lead to conflicts between people and wildlife.
Possible further biodiversity losses in critical habitats.
Has any Local Environmental Expertise been identified? If so, please describe.
The Forest Department of Coxâ&#x20AC;&#x2122;s Bazar South is very active in the area where the Rohingya live.
Several environmental analyses (e.g. that on biodiversity) were carried out by government bodies and local
NGOs before the first Rohingya arrived in the area.
Numerous UN agencies, governmental organisations and NGOs are working in the area. Many of those
present are dealing with environmental issues within the campâ&#x20AC;&#x2122;s footprint as well as outside of the camps.
Are there any required environmental assessments to be carried out (i.e. according to national laws,
international laws, donor requirements)? If so, where are these recorded?
No. National regulation does not appear to require a formal EIA for the influx.
There are at least three recent reports on the EIA providing baseline information for the Kutupalong
makeshift camp area:
An Investigative Environmental Impact Assessment for Kutupalong Refugee Camp and Surroundings,
Bangladesh; Preliminary research, analysis, recommendations, and work breakdown structure for in situ EIA
team. University Centre of the Westfjords, Iceland, October 2017, 61 pages;

79

IOM & FAO (2017). Assessment of fuelwood supply and demand in displacement settings and surrounding
areas in Cox’s Bazaar District, Dhaka, Bangladesh; and
WFP (2017). SAFE Assessment. November 2017, 13 pages.
Potential Implementing Partners
It is important to identify qualified implementing partners as early as possible. Using the form below, select
those categories that seem to most accurately qualify the organisation’s areas of expertise and possible
intervention.

Any other general observations:
Dealing with betel leaf and commonly used nuts.
CHECKLIST 1 – SITUATION ANALYSIS SUMMARY

80

Priority Issues
Comments
Emerging from Notes

Action and Timeframe
(immediate, further
investigation required, no
action needed)

Propose effective
replacement or
reduction of fuelwood
use for cooking

Has started; must be
extended as rapidly as
possible

Introduction of improved cooking stoves; distribution
of small ration of fuelwood from controlled sources;
production and distribution of rice husk briquettes;
substitute fuelwood with other energy sources.
Awareness-raising programmes on different topics.
IGA could be introduced to promote efficient stoves.

High likelihood of recurrent environmental hazards may mean that the
environment is already stressed, at high risk or fragile.

Ungoverned access to
natural resources.

H

If the Rohingya people have free and uncontrolled access to natural
resources such as trees, land, and water, the situation may quickly and
irreversibly get out of control, resulting in e.g. deforestation, ground
water depletion, soil erosion and loss of livelihood for themselves and
for the host communities.

Poor local governance.

M

If local government or community law is unable to restrict uncontrolled
access to natural resources, and no steps are taken to mitigate this
situation, negative environmental impacts can be anticipated.

Lack of self-sufficiency.

M

Rohingya people who are already self-sufficient will normally have
a lower impact on the environment; those unable, to reach selfsufficiency will be a burden.

Lack of supplies, resources
or saleable skills among
Rohingya or returnees.

M

Lack of resources or skills can easily result in environmental damage
through natural resource extraction. Note that subsistence skills or the
keeping of livestock other than as a short-term supply of meat should
be considered carefully, as both may potentially involve additional
natural resource extraction.

Lack of cultural
homogeneity: The degree to
which Rohingya people hold
similar cultural beliefs and
practices among themselves
and with local populations.

L

A lack of common cultural structure may result in disagreement over
natural resource use.

Lack of social solidarity
among the Rohingya and
between Rohingya people
and local populations.

L

Low solidarity may indicate the likelihood of conflict over resources
and limits to the ability of Rohingya people to meet their needs.

Lack of capacity to absorb
M
waste: The environmental,
social and physical structures
available to handle waste
produced by camps
operations.

Poor environmental
resilience: Ability of an
ecosystem to recover from
additional environmental
stress or damage.

H

Low resilience likely means high fragility and greater possibility of
environmental damage. Here H means potentially high environmental
resilience of the area due to high level of precipitation, fertile soils and
tropical climate.

OTHER OBSERVATIONS (including any unresolved discrepancies that arose in discussions)
FINAL RECOMMENDATIONS FOR ACTION
1 Afforestation, reforestation in adjacent areas to offset the loss of forestry.
2 Protection of people from elephant rampages.
3 Protection of remaining forests in the influx area by lessening the demand for wood and bamboo.
4 Stabilsation of slopes of the hills before the next monsoon rains.
5 Finding out stable source for potable water supply.
6 Solid waste management: collection and disposal of solid waste. Fecal sludge management.
7 Livelihood improvements in host communities and camps.
8 Conservation and enhancement of protected areas to ensure no net loss in biodiversity.
9 Improve indoor air quality by promoting use of LPG and high-efficiency stoves and community cooking
outdoors.
10 Set up make-shift bathrooms with tube-wells at convenient distances for women to be able to use the
facilities regularly. Set up separate toilet blocks for women only at convenient distances. Arrange adequate
lighting at the toilets for safety measures.

95

Next Steps
UNDP will decide how they want to contribute to the next Humanitarian Response Plan from March to
December 2018.
Persons/groups consulted for the REA (e.g., UNHCR staff, government representatives, local authorities, traditional authorities, local stakeholders)
Federation of Red Cross, UNHCR, UNICEF, FAO, Site planners and WASH Experts from SDC-SHA, Dept. of
Forest, (i) NGO, MoEF, MoDMR, RRRC, COXâ&#x20AC;&#x2122;S BAZAR IUCN, ARRONYAK FOUNDATION, IUCN.
Who participated in the REA mission:

The Rohingya influx after 25th August 2017
has been continuous and on a large scale.
The Government, with the help of UN
agencies and bilateral support of other
supporting countries, is addressing the
problem.
Forestry and the environment have been
victims of the circumstances.
Expectation from the study team is to get
an understanding about the reversible and
irreversible damages and the means to
contain/offset them.

Meeting with
MoEF

26th October,
2017

Additional
Secretary
Joint Secretary
(Environment)

Concerns about
forestry damage.
Concerns about
contamination of
ground water and
surface water.

Concerns about forestry damage both
natural forest and plantation, concerns
about ECAs and Protected Areas.
Expectation from the study team is to
get an understanding about the loss and
damage in the forestry sector and means
for restoration.
Concerns also include contamination of
ground water and surface water and about
their likely cleaning operation.

Expert
Consultation

28th October
2017

BFD, DoE,
MoEF, FAO, UN
WOMEN, NGOs

Informing and
updating all
relevant ministries
and line agencies,
experts and key
stakeholders
about the REA,
identifying info
and knowledge
gaps and
gathering views
and advice to
design a robust
environment
impact
assessment and
mitigation plan.

Hill-cutting, tree-felling for fuelwood,
withdrawals of huge amounts of ground
water, and pollution from fecal sludge.
Key factors for health and environmental
concerns include the polythene wastes
from relief operations and increased dust
particles in the air from increased traffic.
Some Rohingya have settled in areas that
are likely to face landslides in next yearâ&#x20AC;&#x2122;s
rainy season. It is critical to learn the
resource-use behavior of the Rohingya
to determine the types and extent of the
future environmental impact.
Gender aspects of the crisis are very
important to consider as the majority of
the Rohingya are women and children.
Determining the role of Rohingya women
in impacting the communities and
environment is very important. Rohingya
women stay in their houses most of the
time, so the REIA teams should visit the
households to collect data and build
relationships.

1.The IOM&FAO assessment defined an
AOI and the UNDP Assessment may use a
different AOI. Therefore, it should be noted
the different results may occur from the
different UN organizations. It is helpful
to be consistent whenever possible. For
example, using the same AOI and building
from results already reported in the IOM &
FAO assessment.
2. Unlike the Landcover map, the
Bangladesh Forest Department tree cover
map is finalised and shareable.
3. Follow up may include further
collaboration around the points discussed
above.

First-hand
briefing about the
situation.
Info about the
old and new
shelters, reception
facilities, Site
management,
Involvement of
UN agencies,
NGOs and
the overall
coordination
mechanism

Rohingya first came in the ‘70s, then in the
‘90s, and in 2016. Since August 25, 2017, the
influx has surpassed all records. Over half a
million Rohingya have arrived in this short
period.
The government is providing humanitarian
assistance. The problems are addressed
with the support of UN agencies.
About 4,000 Acres of land / forestry have
been sacrificed.
Not a single Rohingya person is suffering
from starvation. Every family has been
provided with shelter.
3 Brigade of Army and over 2,600
government officers and staff are now
engaged in the site management and its
operation.

CXB office has a miniature lab, capable of
monitoring Physico chemical parameters of
water and waste water.
Trained laboratory assistants are available.
They are willing to conduct the required
field monitoring.

Meeting with
DoF (South)
of Forest
Department

Meeting with
International
Red Cross
(Water
Emergency
Unit)

02 Nov, 2017

03 Nov, 2017

Mr. Ali Kabir

Mr. Gavin

Availability of
maps
Info on plantation
programme and
coverage.
Loss and damage
of forestation in
hectares

Updated maps covering the extent of
damage are not available.

Discussion on
water
and sanitation

Shallow wells are around 20 metres deep.
These wells may survive for another 2 to 3
months maximum.

Around 3500 Acres of hill forests have
been completely lost.
All the plantation forest in the footprint
area has gone.

Test results of well water show around
70% are contaminated with E-coli
No arsenic found
Need to find deep aquifer. Plan to dig a
huge deep tube well to draw water

Meeting with
WASH sector
group

04 Nov, 2017

Sector
coordinator
and other
members

Area of work
Concerns

Ground water has iron as natural
contaminant. Microbial water quality is also
a concern
Uncontrolled use of ground water
Inappropriate management of waste and
sludge construction of latrines without
proper design
Improper desludging and landfill

Presentation of key findings and
recommendations on the REIA study,
including physical impacts and impacts on
ecosystems in the area. Mitigation measures
and proposed programmes. Discussed the
disclosure plan for the report.

Presentation of
key findings and
recommendations
on the REIA study

The amount of forest area Rohingya have
occupied in Ukhia and in Teknaf up to this
influx. The list of plantations they destroyed
range wise. What were the plantation years
and what were the species? At what age
were the plantations cleared up. How much
natural forest land did they occupy?

99

List of people and organizations met and consulted with during UNDP missions

CLASS_Agg means aggregated land cover classes, e.g. Forest Plantation, Orchards and Other Plantations
(Trees) and Rubber Plantation. These were aggregated in one class - Plantations and Orchards.
Baseline means the total area of certain land cover class in the AoI
Current means the total area of certain land cover class within the new campsâ&#x20AC;&#x2122; footprint.
Projected 5 km means total area of certain land cover class in the 5 km buffer zone around the new
camps, excluding camps footprint.
Projected 10 km means total area of certain land cover class in the 10 km buffer zone around the new
camps, excluding campsâ&#x20AC;&#x2122; footprint, but including 5 km buffer.